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Delivering Vital Compliance Training Worldwide
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.
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. read more…
Interactive Sanctions Map
OFAC Enforcement Actions Database
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- CELEX:32017R1834: Commission Implementing Regulation (EU) 2017/1834 of 9 October 2017 amending for the 279th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations