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sanctions

Nigel Morris-Cotterill

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: 
chiefofficersnet

“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: 

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.

Editorial Staff

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.

Publication: 
chiefofficersnet

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: 

Andreea Tampu

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

Publication: 
chiefofficersnet

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."

Five foreign subsidiaries of Thermon Manufacturing Company, a San Marcos, Texas-based firm, have agreed to pay a total of USD176,000 in combined civil penalties.

CoNet Section: 

This list applies to all financial services businesses operating in the UK and their overseas branches and subsidiaries.

Anyone identifying these persons should act in accordance with their reporting and other obligations.

Australia: Reserve Bank of Australia (updated 9 November 2001)

If this list returns a positive match, contact your regulator and seek guidance. The information in the list is current as at 3 October 2001. Although this list is produced by The Reserve Bank of Australia, it has international application.

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