| | | Effective PR

Sanctions In Action

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.


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.


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.


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.


PleaseBeInformed.Com is published by Vortex Centrum Limited, part of The Anti Money Laundering Network group of companies. We began life as a money laundering risk management consultancy in the mid 1990s. Since then, we have expanded to include a wide range of information services, training and education.

We have created crowd-sourced databases of financial crime risk information under the banner GlobalKYC. The business model is to include only facts, with no opinion or comment. Information is entered by its originator, not by a third party. It is therefore unfiltered information directly from the source.

GlobalKYC is the only publicly-accessible worldwide register of certain types of Court or Administrative Order and Crypto-Asset Accounts which are used by criminals.

This page relates to the Crypto-Asset Accounts section and explains how you can become a contributor.

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.


Sanctions have long been a political tool for the USA and they work in many different ways. Chinese telecoms giant ZTE has found itself almost a proxy in the USA's battle with Iran but there are other complexities, too. The result is that President Trump is finding that politics has far more nuance than he thought. The place where he's chosen to try to remove nuance is sanctions. Anyone who still thinks that Trump can't throw out rule-books that have been used for years is flying in the face of the evidence. It would be unwise to bet against him getting the result he wants this time.


Prices are subject to UK VAT as applicable.

Let it be clear from the beginning that I am not talking about trade finance.

The international shipping scenery is characterized by the presence of numerous intermediaries that offer different services to vessels that cross international waters and stop in international ports.

Andreea Tampu is a Certified Compliance Officer with a bank in Romania


The news headlines scream about attacks on UK banks by the USA's law enforcement agencies and regulators enforcing the USA's sanctions policies. But while the focus of attention has been on Standard Chartered, HSBC and others, there is a much bigger pool of targets. Any business that has any form of footprint in the USA, or which transacts in US dollars, faces risks that are similar to those so heavily publicised in relation to banks. Nigel Morris-Cotterill, Head, The Anti Money Laundering Network, explains how this affects businesses all over the world.