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.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.
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…)
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…)
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”).