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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.


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.

BIScom Subsection: 

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.

BIScom Subsection: 

In a notice issued by the Hong Kong Monetary Authority at or about 17:30 today, Hong Kong time, Carmen Chu, Executive Director (Enforcement and Anti Money Laundering) says "The adequacy of sanctions screening systems and controls is a supervisory priority for the HKMA, especially in the light of recent geopolitical developments." The notice is serious reminder to stored value facilities licensees that even though, mostly, the amounts involved are small, the regulatory requirements are not significantly diminished in some important areas.

FCRO Subsection: 

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: 

HM would not be amused. The UK Treasury, which is increasingly given to adopting American terminology, recently issued an "advisory" relating to jurisdictions with deficiencies in their counter-money laundering and anti-terrorist financing regimes. Hilariously, it was identified as a possible scam by the Thunderbird e-mail client.


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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


Far from providing leadership, the USA is increasingly creating friction with allies and alienating itself from countries that don't agree that ratcheting up sanctions against other countries is the best way to go. Add in the decision to recognise Jerusalem as the capital of Israel (and only Israel) and there is an increasing risk that the tables might turn and countries begin to apply sanctions against the USA. If that was to happen, what form could they take and which countries could be caught in the cross-fire?

CoNet Section: 

Yesterday, the USA named several people under the OFAC Specially Designated Nationsls "SDN" list. They are all PEPs in Venezuala so they have gone from "be careful with.." to "don't touch."

Chinese telecommunications giant ZTE and its subsidiaries and associates were investigated for "apparent" breaches of US sanctions, in particular a trade embargo with Iran.

Zhongxing Telecommunications Equipment Corporation is incorporated in China and has subsidiaries and "affiliates throughout the world that conduct business on ZTE and on its behalf," according to OFAC.

A civil penalty has been applied. No prosecution will take place. There is a finding of no fault despite what OFAC calls "an egregious case."

The cult of paying various US government departments, or "agencies" to say nothing of state prosecutors, to to avoid prosecution using the dubious formula of "without admitting or denying the allegations" has reached a new height as a Canadian banking group has "agreed to remit USD516,105 to settle its potential civil liability."

Note "potential." Are such deals evidence of bribery ("we'll give you money if you leave us alone") or of blackmail ("give us money or we'll cost you a fortune in dealing with a long and complex, and heavily disruptive investigation that we all know will turn up something in even the best run companies. And yes, of course we know you aren't American")

The trouble is: there were extensive compliance failures and, as in so many cases, a failure by a non-US bank to recognise the long arm of US law and regulation where US dollars are used.

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On this page are lists of sanctions updates from governments around the world.

The announcement by the US Treasury that it was implementing financial sanctions against North Korea should make no difference to most properly advised financial organisations.

BIScom Subsection: 

The UK Treasury has issued a notice bringing into effect additional requirements. Under the notice issued 6 May 2016, by 31 May credit and financial institutions must terminate all financial dealings with the government of North Korea, with the ruling Party - and essentially freeze the whole of North Korea out of the UK banking system by, amongst other things, closing branches and accounts.