Essentials
Articles
History suggests that effectiveness of economic sanctions may depend on targeted measures
By: Anna Sayre, reporter SanctionsAlert.com
Date: June 23, 2016
Despite a checkered history, the use of sanctions as an international means of effecting change has grown exponentially in recent times. As countries becomes less and less keen to use military force, the world has turned to sanctions implementation as a means of affecting international change, both politically and socially. (more…)
U.S. Constitution reference to ‘Marque and Reprisal’ presaged sanctions today, laid foundation with pirates as protagonists
By: Kenneth Barden *
Date: April 20, 2016
A little-noticed provision of the United States Constitution established the foundation for the economic sanctions in force today. Article I, Section 8, of the Constitution authorizes Congress, “To… grant Letters of Marque and Reprisal …;” , Thus empowering the legislative branch to authorize private parties to seize and hold assets of foreign enemies. This grant of authority played an important role in the early days of the new nation and helped the U.S. combat foreign aggression. (more…)
‘Special measures’ are a distinct type of sanctions imposed by FinCEN, an OFAC sister agency at Treasury
Date: April 15, 2016
The United States sanctions regime is not localized exclusively in the US Treasury Department’s Office of Foreign Assets Control. That’s one reason why sanctions compliance officers have a tough job. They must not only keep up with the sanctions programs announced by the president and enforced by the Treasury Department. They must also solely, or in conjunction with fellow compliance officers in the anti-money laundering wing of the organization’s compliance department, comply with “Special Measures” that the same Treasury Department imposes routinely under Section 311 of the USA Patriot Act. (more…)
Federal Financial Institution Examination Council (FFIEC).
Date: March 28, 2016
United States Bank examiners are instructed in their work by an extensive "Examination Manual” issued by an umbrella U.S. government agency called the Federal Financial Institution Examination Council (FFIEC). (more…)
It may surprise money laundering compliance officers
Date: March 28, 2016
It may surprise money laundering compliance officers and others who know the money laundering and financial crime provisions of the USA Patriot Act to learn that the law contains a "Trade Sanctions" provision. Section 221 of the landmark act sought to tighten trade sanctions and export controls aimed at terrorists and nations and organizations that pose threats to the U.S. (more…)
Potent US money laundering law lists sanctions violations as a “Specified Unlawful Activity”
Date: March 28, 2016
Listed among the more than 220 "specified unlawful activities" (SUA) that can serve as predicates to a US money laundering prosecution is Section 206 of the International Emergency Economic Powers Act (Title 50, US Code Sec. 1705). (more…)
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