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. (more…)

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…)

The Complexities of Dealing with Iranian Business Counterparts – Tips and Practicalities

January 8, 2018

Since the implementation of the Joint Comprehensive Plan of Action, or JCPOA, in early 2016, the international community’s plan to slowly ease sanctions against Iran has led to banks and financial institutions becoming increasingly unsure about which transactions are allowed and which are still too risky to undertake. As such, compliance officers and other professionals have had to navigate extremely treacherous waters. (more…)

UPDATE: Congress Passes Sweeping Iran, Russia, and North Korea Sanctions Legislation

By Alexis Early*
July 27, 2017

On July 27, the Senate passed 98-2 the Countering America’s Adversaries Through Sanctions Act (HR 3364), which previously passed the House 419-3 on July 25, setting up a showdown with President Trump. This bill is an omnibus of three separate sanctions measures: the Countering Iran’s Destabilizing Activities Act (“CIDAA”), the Countering Russian Influence in Europe and Eurasia Act (“CRIEEA”), and the North Korean Interdiction and Modernization of Sanctions Act (“NKIMSA”).

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Indictment of Lebanese Businessman, Tajideen, Points to Bold Methods of Sanctions Enforcement by DoJ and May Trigger Compliance Headaches for Banks

July 14, 2017
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

On March 24, 2017, Kassim Tajideen, an international financier and businessman operating a network of businesses in Lebanon and Africa, was charged by the U.S. Department of Justice (DoJ) with evading sanctions by purposefully concealing his association with certain companies, the profits of which were used in part to support the Shiite militant movement Hezbollah. This terrorist group was also designated by the U.S. Department of State as a Foreign Terrorist Organization in 1997. Tajideen, who was extradited from Morocco to the U.S., pleaded not guilty to all 11 counts. (more…)