Bank of China Order Confirms U.S. Regulators Are Willing to Take a Tough Line On Sanctions Missteps

August 16, 2018
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

After conducting a supervisory examination of its compliance program, the Office of the Comptroller of the Currency (OCC) has issued a $12.5 million fine and a Consent Order requiring Bank of China’s New York Branch to fulfill certain requirements within 90 days, some very far-reaching.

The Order, imposed by the OCC in April 2018, not only details shortcomings found in the Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program of one of the world’s biggest lenders, but also enterprise-wide deficiencies in its Office of Foreign Assets Control (OFAC) compliance requirements.

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The Benefits of Incorporating Cutting-Edge FinTech Technologies Into Your Sanctions Screening Program

July 17, 2018
By: Joseph M Bognanno, Chief Innovation Officer, Safe Banking Systems and Ben Knieff, Financial Crimes Expert, Safe Banking Systems*

Financial institutions, and increasingly corporates and non-financial institutions, face the unrelenting challenge of combating those who wish to evade sanctions, money laundering and terrorist financing. A keystone in any effective approach to meeting this challenge is the identification of entities as part of the organization’s Know Your Customer (KYC) program, which always includes screening. (more…)

Seven Reasons Why Compliance Suites Should Treat Sanctions As Distinct from AML

July 7, 2018
By: SanctionsAlert.com

In recent times, the implementation of economic sanctions has been the go-to method for governments to put pressure on those countries that do not adhere to international standards. The implementation of economic sanctions as a leveraging tool has grown exponentially in the last decade and, as a result, given rise to a myriad of new rules and regulations that compliance suites must follow or suffer the consequences.

Nevertheless, despite this influx of new sanctions-based requirements, many compliance suites still continue to embedsanctions into their overall Anti-Money Laundering (AML)programs.

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‘Sanctions Busting’: The Risks and Rewards to those Trying to Circumvent the System

June 15, 2018
By: Keith Preble and Dr. Bryan R. Early*

The main goal of imposing sanctions on a target country or entity has always been to disrupt the target’s commercial relationships and make it costlier for them to do business. Governments try to achieve this goal by imposing administrative and criminal penalties for individuals and entities that violate their sanctions.

Though these restrictions generally apply only to firms and citizens operating in the country imposing the sanctions, the United States has recently employed far more aggressive and wide-reaching methods in penalizing foreign firms.

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Wake Up To Sanctions

SanctionsAlert.com Sanctions Round Up
May 30, 2018

FinCEN CDD Rule Comes into Effect; FFIEC Issues Guidance for Compliance Suites, including for OFAC Officers

On May 11, 2018, exactly two years after being issued, the Financial Crimes Enforcement Network (“FinCEN”)’s implemented its new Customer Due Diligence (CDD) Rule. This CDD rule enhances CDD requirements and also adds a new requirement for financial institutions to identify, and verify the identity of, the beneficial owners of certain legal entity customers.

OFAC Compliance Officers should take notice, as US Treasury expects financial institutions to use beneficial ownership information not only to comply with AML requirements, but also for compliance with the OFAC regulations.

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U.S. Shocks the World by Withdrawing from Iran Nuclear Agreement; OFAC Issues Important Deadlines for Compliance Suites

May 9, 2018
By: Saskia Rietbroek, Principal, SanctionsAlert.com

On May 8, 2018, President Trump announced that the U.S. would be withdrawing from the Iran nuclear deal. The agreement, officially known as the Joint Comprehensive Plan of Action (JCPOA), was reached in 2015 by Iran and major world powers – U.K., China, France, Germany, Russia and the U.S (the ‘P5’) in hopes of halting Iran’s nuclear capabilities. The decision to withdraw leaves the JCPOA in tatters and creates a host of new challenges for sanctions compliance officers worldwide.

“It has turned my world upside down,” says a compliance officer from an international insurance company.

The U.S. government says it will restore the strict sanctions it imposed on Iran before the 2015 deal and is considering new penalties. It is important to note that the JCPOA is not a treaty, but rather a political arrangement put into force largely through presidential executive orders, which the President can revoke without the approval of Congress. (more…)