Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”.[1] Collectively speaking, regulatory bodies have not explicitly defined what this […]
A core tenet of economic sanctions is that they are more effective when they are imposed multilaterally, as that presents fewer alternatives for the targeted parties to continue their sanctioned activities. The past year, however, has shown few, if any, attempts at coordinated action. In fact, if anything, 2020 was more of a year in […]
Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive. AMLD6 has a compliance date of 3 December 2020. The Directive increased the number of predicate offense categories to twenty-two. The newly […]
Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]
On June 16th, President Donald Trump, to much fanfare, announced he was “canceling the last administration’s completely one-sided deal with Cuba”. Despite the implication that the changes to the Cuban sanctions program made over the prior two years by the Obama Administration would be largely reversed, a closer look reveals that the changes are significantly more […]
How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system? That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of this […]
As part of international efforts to prevent further development of Iran’s nuclear weapons program, on December 31 2011 the United States (US) imposed various ranges of diplomatic and legal sanctions to prevent foreign financial institutions (FFI’s) from conducting transactions with Iran through the US Department of the Treasury; Office of Foreign Assets Control (OFAC) regulations. […]
