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Sanctions In Action

Collected government notices relating to sanctions around the world. If your government department issues an RSS feed of sanctions notices, please let us know so that we can add it to this section.

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Deutsche Bank will, in the not too distant future, become a cause of study in universities, colleges and business schools across the world. It will become the iconic example of how not to run a bank.

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Essentra FZE Limited, a manufacturer of cigarette filters and tear tape has agreed to forfeit USD 665,112 in respect of "apparent" breaches of US sanctions relating to North Korea. Essentra is a company registered in the United Arab Emirates with no physical presence in the USA.

The USA describes it as "egregious."

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This is the full text of the UK's initial sanctions list published 6 July 2020, segregated into topics. We have also reproduced the UK's statement about the status of sanctions.

See here for commentary.

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The USA and Israel are the two most prominent countries which refuse to recognise the International Criminal Court. But the International Criminal Court takes action where it finds it. And US President Trump doesn't like it when US Citizens are affected. Now he's taken the remarkable step of issuing an Executive Order on 11 June 2020 applying sanctions to those involved in the Court. And he's declared a national emergency.

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According to a statement issued by the USA's Office of Foreign Assets Control (it's primary financial and economic sanctions department which also investigates and takes action in respect of breaches) says this "Between approximately March 26, 2015 and May 19, 2015, American Express Travel Related Services Company (“Amex”) issued a prepaid card to, and processed 41 transactions totalling $35,246.82 on behalf of, Gerhard Wisser,a Specially Designated National (SDN)."

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Open General Licences - clarification on recent changes by the Export Control Joint Unit.

Webinar : 16 March at 11:00 GMT.

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OFAC has issued a "Finding of Violation" in respect of breaches of the Global Terrorism Sanctions Regulations relating to the maintenance of Iranian-owned aircraft. The subject of the order no longer exists but OFAC has proceeded anyway.

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If we take out the hyperbole inherent in American notices (e.g. "violation" instead of "breach" and the profligate use of words like "egregious") we get to a nitty gritty that is a stone in the shoe, a thorn in the side or any one of a dozen bon mots that indicate how and why compliance officers need to be abreast of principles more than data. One has to feel some sympathy with State Street. The case also have implications for citizens of one country living abroad, especially pensioners.

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Any business that does business in or via the USA, including doing business in US Dollars is subject to US sanctions law. The USA frequently punishes foreign businesses which it says has breached its sanctions law. While the media focus is usually on action against UK and EU banks, the simple fact is that successful actions have been brought against, even, individuals buying and selling goods via eBay. So, when the US Treasury says "this is how to design your compliance system," it makes a great deal of sense to pay attention. Yesterday, that's what it said. So pay attention.

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The USA's Office of Foreign Assets Control has reached an agreement with a company from Connecticut over "apparent violations" of US sanctions against Iran.

Hang on... "apparent violations"? And the company has agreed to pay? It's time to abandon the linguistic and legal pussyfooting around.

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On 2 July, 2018, OFAC issued a recent action notice [ https://www.treasury.gov/resou... ] notifying persons holding property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations of the requirement, as outlined in 31 C.F.R. 501.603, to provide OFAC with a comprehensive report on all blocked property held as of June 30 of the current year by 30 September.

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