October 29, 2018
By: Scott Nance*
In order to optimize interest and improve liquidity for their clients, financial institutions frequently maintain so-called ‘pooling accounts’, in which funds from many different accounts are combined. Funds in such accounts may belong to multiple persons or belong to only one person, but are often used to make payments to a number of other parties on a periodic basis. Pooled accounts are often used to settle balances between these different entities. (more…)
October 3, 2018
On September 13, 2018, Epsilon Electronics Inc, a car audio and video equipment manufacturer, agreed to pay the U.S. Treasury’s Office of Foreign Assets Control (OFAC) $1,500,000 to settle a case related to alleged violations of the Iranian Transactions and Sanctions Regulations.
The case, which is a culmination of a 2014 penalty notice and two court cases, contains four vital lessons for U.S. exporters whose products may be found in Iran. (more…)
SanctionsAlert.comSummer Sanctions Round Up
September 5, 2018
U.S. Cracks Down on Russia with Global Magnitsky Regulations and New Sanctions
As of June 29,2018, the Global Magnitsky Sanctions Regulations (31 CFR part 583) took effect on the Federal Register. These regulations implement the Global Magnitsky Human Rights Accountability Act (or U.S. Global Magnitsky Act) as well as Executive Order 13818 of December 20, 2017.
August 20, 2018
By Anna Sayre, Legal Content Writer SanctionsAlert.com
Financial institutions and corporations playa key role in the implementation of sanctions issued by the United Nations (UN) Security Council.In fact, this is where the rubber hits the road, as private companies are the ones that enable the implementation of UN sanctions. Nevertheless, many compliance officers,who deal with the operational aspects of UN-derived sanctions on a daily basis and often spend millions of dollars/euros to ensure compliance, are not aware of how they come into being or the policies from which they derive. (more…)
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.
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…)