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sanctions

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)."

Publication: 

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

Webinar : 16 March at 11:00 GMT.

Publication: 

If you are issuing a notice about technology, the least you can do is make sure your own tech works when recipients click on a link in the notice.

CoNet Section: 

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.

Publication: 

Washington 5 December 2019 – Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action against Evil Corp, the Russia-based cybercriminal organization responsible for the development and distribution of the Dridex malware.

BIScom Subsection: 

The USA's cyber-security agency, US-CERT, has issued an alert relating Dridex Malware which targets the financial sector. It follows work by various government departments including FinCEN.

FCRO Subsection: 

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.

Publication: 

The UK's Department for International Trade has issued a new, contingency version of the Open General Export Licence (OGEL) for dual use goods exported to countries within the UK.

The bringing into force of the new licence is contingent upon the UK leaving the European Union without a deal. If there is a deal, the existing arrangements will continue at least during the transitional period. However, there is something odd going on..

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.

Publication: 

The US Department of the Treasury will shortly modify the website at www.treasury.gov. The change will affect, inter alia, users of the OFAC sanctions lists. A notice, reproduced below, verbatim, informs users about the changes.
BIScom Subsection: 

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.

Publication: 

“The charges unsealed today are the result of years of investigative work conducted by the FBI and our law enforcement partners,” FBI Director Christopher Wray said announcing the charges "unsealed" by United States Attorneys Offices in the Eastern District of New York and the Western District of Washington. The list reads as if someone decided to find a copy Title 18 of the US Code and throw it at Huawei Technologies Co., Ltd. Sadly, Wray's language is political and intemperate and undermines the credibility of the action from the outset.

CoNet Section: 

It would be far more sensible if the UK scrapped its money laundering laws, wrote something comprehensible and properly structured and kept it all in one place. But no, that would make life far too simple. So, we have the latest Act that has to be read in the light of, and which makes amendments to, other legislation. But it's important and so no one can simply say "stuff it" and delete it. As it comes into force, there is a hint as to at least some of the priorities in relation to international financial crime.

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BIScom Subsection: 

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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