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sanctions

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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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.

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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.

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“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.

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Case Summary: 

We couldn't pass on the chance to copy and paste the above headline from the USA's FBI media service. The case is about smuggling restricted goods in breach of US sanctions and not about edible nuts.

Type of conduct: 
Sanctions - Breaches

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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Yesterday, US President Trump announced the long-telegraphed withdrawal of the USA from the Iran nuclear sanctions agreement, known as the Comprehensive Plan of Action. According to the US Treasury "The President confirmed that the US will begin the process of re-imposing all US sanctions previously waived under the JCPoA." That's going to cause huge complexity for businesses all over the world because no other government of any international importance is adopting the USA's position. Also, there's a gold-rush about to start.

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Yesterday, the USA's President Trump announced that the US would leave the Joint Comprehensive Plan of Action a.k.a. the Iran Nuclear Deal. Below is a list of resources.

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It might take a stretch of the imagination to join the UK's departure from the EU and the wife-murdering, perhaps syphilitic, definitely unstable, ferociously misogynistic Tudor monarch who is, arguably, the UK's most famous king. But there is a certain logic and the admirably named Lord Judge has applied his considerable legal knowledge and intellect to make that connection and to rightly harry those responsible for the poor legal drafting that plagues English law and, in particular, that relating to the not-admirably named "Brexit." At the heart of his concerns are a major constitutional issue now known as "Henry VIII powers." This month, Parliament is making much of that while debating Sanctions and Anti-Money Laundering Bill.

CoNet Section: 

Titled "PROPOSED CHANGES TO THE DFSA’S ANTI MONEY LAUNDERING, COUNTER-TERRORIST FINANCING AND SANCTIONS REGIME," the consultation paper was issued on 18 February 2018 and the consultation period ends on 24th March 2018.

Notes by Nigel Morris-Cotterill, The Anti Money Laundering Network

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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

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