Tagged: ofac

President Obama Pledges to Lift Myanmar Sanctions

Jacqui Merrill, an associate at The Volkov Law Group, rejoins us for a posting on the Myanmar Sanctions.  Jacqui can be reached at jmerrill@volkovlaw.com. On September 14, 2016, President Obama met with Myanmar’s leader, State Counsellor Daw Aung Suu Kyi, at the White House and announced the United States’ intent to remove economic sanctions against Myanmar (formerly known as Burma) in the near future.  The President...

Anti-Corruption, Sanctions and Export and Import Risks

Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.”   If you are managing corporate risks and are responsible for securing export licenses, ensuring that you are complying with OFAC sanctions requirements, interacting with customs and immigration officials around the globe, and conducting third party due diligence to onboard a new agent or distributor, there is no question that...

New York Department of Financial Services Issues New AML and Sanctions Regulations

The New York DFS finalized its new AML and Sanctions screening regulations. Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the bank or other covered entities maintain an adequate AML and sanctions compliance program. In its place, the NYDFS regulations require an annual certification from senior management, i.e. those responsible for “management,...

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered the sanctions landscape with the Iran Nuclear Treaty, and major changes in its relationship with Cuba and Myanmar (Burma). Since the major changes have been announced or implemented, there have been continuing...

FinCEN Issues New Beneficial Ownership Regulations

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...

Panama Papers: Looking Below the Headlines

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...

Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance.  She can be reached at lconnell@volkovlaw.com. 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....

Beneficial Ownership: Sanctions and FCPA Compliance

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,...

Webinar: Review of Iran and Cuba Sanctions Programs — Compliance Challenges

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...

The Changes to Iran Sanctions and Compliance Challenges

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)....