April 10, 2020
By: Anna Sayre, Director of Content, ACSS
On March 31, 2020, France, Germany, and the U.K. confirmed concluding their first INSTEX transaction between the E.U. and Iran, by successfully exporting medical goods to the Middle Eastern country. Though the types of goods allowed under the trade mechanism remain limited, this transaction marks a significant step in allowing E.U member states to continue trade with Iran despite the re-imposition of U.S. sanctions. (more…)
The Blocking Statute – Deciphering its Provisions, How to Handle the EU/US Conflict, and Actions to Date
March 31, 2020
By: Jack Walsh, Content Writer, ACSS
A 2018 annex to the E.U. Blocking Statutehas created a formidable compliance dilemma for European companies that wish to cease business operations in Iran. Enacted to mitigate the effect of reinstated U.S. sanctions on Iran, the amended statute penalizes any E.U. companies that acquiesce to U.S. demands, placing companies in a seemingly untenable position. The challenge for compliance officers will be to navigate these contradictory demands in a world where two of the biggest players in the sanctions arena do not agree. (more…)
March 25, 2020
By: Glenda Juliano*, CAMS, CSS
The U.S. withdrawal from the JCPOA and the return of sanctions has had a substantial impact on European companies that have increased their trade with Iran since 2015. Today, European businesses operating in Iran in violation of U.S. sanctions are at risk of being banned from the U.S. market.
March 17, 2020
By: Natasha Bright, Content Writer, ACSS
Both the European Union and the United States consider Iran to be a threat to the region and the world. One of the tactics that both jurisdictions take to limit Iran’s power is to isolate the country from the global economy. In 2015, Iran entered into the Joint Comprehensive Plan of Action (JCPOA), a nuclear accord whereby Iran promised to curb movement toward the development of a nuclear weapon in exchange for the easing of sanctions.
June 12, 2019 By: Anna Sayre, Head of Legal Content, ACSS
In early 2019, despite U.S. sanctions to the contrary, Germany, France and the U.K. (also known as the ‘E3’) joined together to set up INSTEX: a new payment channel to facilitate trade with Iran. Though a bold move in theory, any effort on the part of the E.U. to continue trade with Iran could only serve to ruffle Washington’s feathers.
SanctionsAlert.com Sanctions Round Up
May 30, 2018
FinCEN CDD Rule Comes into Effect; FFIEC Issues Guidance for Compliance Suites, including for OFAC Officers
On May 11, 2018, exactly two years after being issued, the Financial Crimes Enforcement Network (“FinCEN”)’s implemented its new Customer Due Diligence (CDD) Rule. This CDD rule enhances CDD requirements and also adds a new requirement for financial institutions to identify, and verify the identity of, the beneficial owners of certain legal entity customers.
OFAC Compliance Officers should take notice, as US Treasury expects financial institutions to use beneficial ownership information not only to comply with AML requirements, but also for compliance with the OFAC regulations.