Under the dark cover of the Panama Papers scandal, FinCEN moved quickly to issue its beneficial; ownership regulations. For all of the US regulatory and financial industry bluster, it is about time. The United States stands far behind other countries in requiring transparency with regard to financial ownership. It is unfortunate that it took the Panama Papers scandal to give FinCEN the political opportunity to...

The media loves a scandal. In the banking and compliance world, the latest scandal to hit the media was the Panama Papers. The Panama Papers is surprising in scope – Panama has become the favorite financial haven for money launderers, PEPs and other miscreants. We have all seen this in the business world as Panamanian banks grew in rapid fashion. As the Cayman Islands, Switzerland...

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance.  She can be reached at [email protected]. Implementation Day has been hailed as a new stage in Iran-US relations. There has been significant media coverage of how sanctions are being lifted, with various outlets suggesting that Iran is now “open for business.” In reality, that is far from true....

Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of FinCEN’s proposal is diminishing. Why? In general, businesses have other reasons to secure beneficial ownership information. One key concern is sanctions compliance. To the extent an account holder engages in international transactions,...

Review of Iran and Cuba Sanctions Programs — Compliance Challenges February 16, 2016 12 Noon EST Sign Up Here The US government has implemented major changes to the Iran and Cuba sanctions programs. Recently, the Treasury Department’s Office of Foreign Assets implemented major revisions effective on Implementation Day under the US-Iran Nuclear Agreement. For compliance professionals, the revised restrictions raise serious compliance challenges.  In addition...

Putting aside the politics surrounding the Iran Nuclear Deal, the exchange of prisoners and other hot button political issues surrounding Implementation Day and the change in US-Iran relations, the new Iran sanctions create a new set of challenges for trade compliance officers. Talk about a headache — all you have to do is look at the new guidance, Frequently Asked Questions, and related documentation (Here)....

Deutsche Bank agreed to pay $258 million and fire six employees to resolve a New York and Federal Reserve investigation for sanctions violations from 1999 to 2006. The settlement is big news but ignores three key players who are continuing to investigate Deutsche Bank: the Justice Department; the Treasury Department’s Office of Foreign Assets Control (“OFAC”); and the Manhattan District Attorney’s Office. Deutsche Bank has...

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement program. Thus far, OFAC has collected approximately $270 million in civil penalties, and participated in several major criminal investigations, including Commerzbank and Schlumberger. Commerzbank agreed to pay a total of $1.45 billion...