The Relatively Little-Known Role of the U.S. State Department in Sanctioning Terrorists and its Consequences

December 5, 2017

In addition to the U.S. Treasury, the U.S. State Department has great influence over the implementation of U.S. sanctions policy in designating terrorists. Despite this important role, over 90% of compliance professionals recently polled by SanctionsAlert.com are either “not so familiar” with the State Department’s designations or “did not know” at all that it could designate.

The imposition of sanctions by the U.S. against terrorists, terrorist organizations, and their support structures is a powerful tool in the detection and prevention of terrorism. (more…)

A ‘Modest Proposal’ for Cuba: OFAC, BIS and State Department Implement President’s New Cuba Policy

November 24, 2017
By: EdKraul and, Brian Egan, Keith Huffman, Meredith Rathbone, Jack Hayes, Anthony Rapa, and Peter Jeydel*

Effective November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR), respectively, to implement changes to US Cuba sanctions policy articulated by President Trump in a presidential memorandum issued June 16, 2017. Concurrently, as required by the presidential memorandum, the Department of State published a list of 180 entities and sub entities associated with Cuban military, intelligence, and security services (Cuba Restricted List).  (more…)

Wake Up To Sanctions

SanctionsAlert.com Sanctions Round Up
November 17, 2017

EU removes FARC from terrorist list; imposes first set of sanctions on Venezuela

On November 13, 2017, the E.U. removed Colombian guerilla group FARC from its terrorism sanctions list following its disarmament and re-launch as a political party. Earlier, in September 2016, the E.U.had suspended its terrorism sanctions on FARC in recognition of the peace agreement signed between FARC and the Colombian government.

(more…)

Sanctions Essentials: Connecting the Dots Between Sanctions and AML

Upcoming Webinar

Date:  Thursday, February 22, 2018

Time:  12:00 PM – 01:15 PM EST

The overlap between Anti-Money Laundering (AML) and sanctions has always been undeniable. In the last 10 years, however, sanctions have emerged as a unique and separate area of compliance carrying heavy civil as well as criminal penalties for failure to comply.

Today, no compliance program is complete without taking AML and sanctions rules into consideration, and ensuring that you and your team fully understands the important convergence between these two regulatory hurdles.

This webinar will provide a practical approach to the similarities and differences between AML and Sanctions rules, as well as what a company can do to stay fully compliant with both compliance models.

Join this live SanctionsAlert.com course and learn:

  • BSA/AML Examination Manual and its role in OFAC compliance program examinations
  • What goes in a blocking/reject report vs. what goes in a suspicious activity report
  • The overlap of sanctions and AML controls concerning activity by designated terrorist groups, militias, and other organizations
  • How to ensure your sanctions and AML teams communicate appropriately with each other (and avoid common misunderstandings)
  • NYDFS Part 504 and how AML concepts are increasingly being applied to sanctions compliance
  • Tools at the disposal of FinCEN, including Section 311 of the USA Patriot Act, which contains a “Trade Sanctions” provision in section 221 of Title II “Enhanced Surveillance Procedures”
  • The intersection between FinCEN’s CDD rule and OFAC’s 50% rule
  • How Section 206 of the International Emergency Economic Powers Act (Title 50, US Code Sec. 1705) is among the 200 “Specified unlawful activities” (SUAs) that can serve as a predicate to a U.S. AML prosecution by DOJ

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OFAC

Duration: 

75 minutes

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 Great knowledge, great instructors, great value

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Certificate of Attendance

If you participate in the live webinar, you will receive a Certificate of Attendance, which you can use to show you meet your government-required training duties.

Tyler Hand
Global Head of Sanctions, Interdiction & Anti-Corruption
Western Union

Tyler’s responsibilities with Western Union include overseeing the company’s Office of Foreign Assets Control and other government sanctions compliance programs, as well as the company’s proprietary list-screening operations. Tyler joined Western Union in June 2014 after working for seven years at the United States Department of the Treasury in Washington, DC. During his time with the Treasury Department, Tyler served as OFAC’s Assistant Chief Counsel for Designations and Enforcement and as Acting Director for Enforcement. While at the Treasury Department, Tyler’s responsibilities included developing and implementing policies related to OFAC enforcement and designation matters, drafting sanctions Executive Orders and regulations, and advising on large interagency enforcement investigations involving major financial institutions. Tyler also served as the primary point of contact for counterparts at the Department of Justice, the Department of State and the White House National Security Staff. Prior to joining OFAC, Tyler practiced law at Holland & Hart in Denver, CO in its Export Controls and Trade Sanctions practice group. Tyler received his JD in 2000 from the University of Colorado School of Law, Boulder, and his Bachelor of Arts in 1995 from the University of Vermont, Burlington.

This Live Webinar is Included in the SanctionsAlert.com Membership. SanctionsAlert.com Members will receive an email with log in details one day before the Webinar. These are also posted on the SanctionsAlert.com Platform. After the Live Webinar, SanctionsAlert.com Members can also view this webinar on-demand on our Platform.

Carlton Greene
Partner
Crowell & Moring LLP

Carlton is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Before joining FinCEN, Carlton previously served as the assistant director for transnational threats with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), where he directed targeting and investigations for more than 15 U.S. economic sanction programs, including those related to Iran and North Korea. Carlton also served as legal counsel to OFAC on counter terrorism sanctions. Previously, he was appointed by the United Nations Secretary-General to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. Carlton also previously served as a trial attorney at the U.S. Department of Justice, where his practice included representing OFAC on sanctions issues.

Based on his years of experience with OFAC and FinCEN, Carlton offers valuable insights on the approaches of these agencies that will assist corporate clients to more effectively respond to government investigations, as well as update their corporate compliance programs in general.

 

Attendee Testimonials

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Bank of America

“Great knowledge from the presenters and the content was relevant”
— José R. Fernandez, Bank of America – Charlotte, NC, USA

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Wells Fargo

“Great coverage of information”
— Cathy Swindell-Smith, Wells Fargo – Charlotte, NC, USA

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Axa Equitable Life Insurance Company

“It was very informative. The speakers were clear and the information was disseminated in a clear, concise manner.”
— Nicolette Douglas, Axa Equitable Life Insurance Company – New York, NY, USA

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RBC

“The content was excellent and easy to understand. The presenters did a great job!”
— Susan Wilson, RBC – Toronto, Canada

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Comerico Bank

“Both speakers were exceptionally knowledgeable and provided practical information regarding the sanctions changes”
— Adam Hermes, Comerico Bank – Livonia, USA

Lessons Learned From the ZTE Case

Upcoming Webinar

Date:  Thursday, January 25, 2018

Time:  12:00 PM – 01:00 PM EST

In recent times, OFAC enforcement actions have significantly increased against non-financial institutions, particularly in IT/telecoms. On March 7, 2017, three U.S. regulators – the Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of Justice (DOJ) – entered into a coordinated settlement with Zhongxing Telecommunications Equipment Corporation (ZTE), in which the company agreed to a record-breaking combined $1.19 billion in civil and criminal penalties for knowingly shipping illegal telecommunications equipment to Iran and North Korea in violation of U.S. sanctions law.

The fines imposed by the regulators represent the largest penalty ever imposed by BIS, and the largest ever imposed by OFAC against a non-financial entity.

This webinar will provide a practical approach as to what a company should do (or should not do) to avoid a fate like that of ZTE and, if penalized, what can be done to regain reputation in your industry and in the eyes of the regulator.

Join this live SanctionsAlert.com course and learn:

  • Details of what happened between 2012 and 2017 when ZTE reached settlement with OFAC;
  • Process of Entity Listing / Temporary General License Process;
  • How to progress from Entity List to Industry Leading;
  • Key challenges for a foreign company complying with U.S. export controls and sanctions laws; and
  • Best practices during a monitor/auditor process after settlement.

Add to Calendar

OFAC

Duration: 

60 minutes

Speaker:

Matt Bell

Moderator:

Anna Sayre, Legal Content Writer, SanctionsAlert.com

Sign up today!

 Great knowledge, great instructors, great value

Tell your friends, clients, customers and colleagues to sign up.

Certificate of Attendance

If you participate in the live webinar, you will receive a Certificate of Attendance, which you can use to show you meet your government-required training duties.

Matt Bell
Chief Compliance Officer & Legal Counsel
ZTE Corporation, USA

Matt Bell is the Chief Export Compliance Officer & Legal Counsel for ZTE Corporation and the Chief Compliance Officer & Legal Counsel for ZTE USA – in this dual role, he splits his time between Texas and China. ZTE is one of the largest telecommunication companies in the world with offices in more than 160 countries and a workforce of more than 80,000 employees globally. Prior to ZTE, Matt worked as the Senior Attorney for Anti-Corruption at KBR, Region Compliance Counsel and Global Trade Counsel at Weatherford International, and in consulting for both Ernst & Young and KPMG’s International Trade practices. Matt received his LL.M. with Honors from the John Marshall Law School in Chicago with dual concentrations in International Finance & International Trade. He received his JD from Faulkner University and his BBA from Oklahoma Christian University. Throughout his career in consulting and as in-house counsel, Matt has worked with multiple companies under investigation or who reached significant settlements with the Department of Justice, OFAC, BIS, and the SEC. Matt enjoys helping companies through these challenges and working with the business leaders to see the Compliance Team as a strategic business partner to support a sustainable growth strategy.

This Live Webinar is Included in the SanctionsAlert.com Membership. SanctionsAlert.com Members will receive an email with log in details one day before the Webinar. These are also posted on the SanctionsAlert.com Platform. After the Live Webinar, SanctionsAlert.com Members can also view this webinar on-demand on our Platform.

Attendee Testimonials

Logo

Bank of America

“Great knowledge from the presenters and the content was relevant”
— José R. Fernandez, Bank of America – Charlotte, NC, USA

Logo

Wells Fargo

“Great coverage of information”
— Cathy Swindell-Smith, Wells Fargo – Charlotte, NC, USA

Logo

Axa Equitable Life Insurance Company

“It was very informative. The speakers were clear and the information was disseminated in a clear, concise manner.”
— Nicolette Douglas, Axa Equitable Life Insurance Company – New York, NY, USA

Logo

RBC

“The content was excellent and easy to understand. The presenters did a great job!”
— Susan Wilson, RBC – Toronto, Canada

Logo

Comerico Bank

“Both speakers were exceptionally knowledgeable and provided practical information regarding the sanctions changes”
— Adam Hermes, Comerico Bank – Livonia, USA