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July 7, 2018
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.
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.
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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- OJ:JOC_2017_339_R_0005: The following information is brought to the attention of ABDOLLAHI Hamed (a.k.a Mustafa Abdullahi), AL NASSER Abdelkarim Hussein Mohamed, AL YACOUB Ibrahim Salih Mohammed, ARBABSIAR Manssor (a.k.a. Mansour Arbabsiar), IZZ AL DIN Hasan (a.k.a. GARBAYA, Ahmed; a.k.a. SA ID; a.k.a. SALWWAN, Samir), SHAHLAI Abdul Reza (a.k.a Abdol Reza Shala’i, a.k.a. Abd-al Reza Shalai, a.k.a. Abdorreza Shahlai, a.k.a. Abdolreza Shahla’i, a.k.a. Abdul-Reza Shahlaee, a.k.a. Hajj Yusef, a.k.a. Haji Yusif, a.k.a. Hajji Yasir, a.k.a. Hajji Yusif, a.k.a. Yusuf Abu-al-Karkh), SHAKURI Ali Gholam and SOLEIMANI Qasem (a.k.a Ghasem Soleymani, a.k.a Qasmi Sulayman, a.k.a Qasem Soleymani, a.k.a Qasem Solaimani, a.k.a Qasem Salimani, a.k.a Qasem Solemani, a.k.a Qasem Sulaimani, a.k.a Qasem Sulemani) — persons included on the list provided for in Article 2(3) of Council Regulation (EC) No 2580/2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism (see Annex to Council Implementing Regulation (EU) 2017/1420 of 4 August 2017)