Risks and Controls
June 15, 2018
By: Keith Preble and Dr. Bryan R. Early*
The main goal of imposing sanctions on a target country or entity has always been to disrupt the target’s commercial relationships and make it costlier for them to do business. Governments try to achieve this goal by imposing administrative and criminal penalties for individuals and entities that violate their sanctions.
Though these restrictions generally apply only to firms and citizens operating in the country imposing the sanctions, the United States has recently employed far more aggressive and wide-reaching methods in penalizing foreign firms.
Wolfsberg’s New Correspondent Banking Questionnaire Incorporates Specific Guidance to Aid in Sanctions Compliance
April 11, 2018
By: Anna Sayre, Legal Content Writer SanctionsAlert.com
In direct response to increased regulatory expectations for enhanced due diligence in correspondent banking relationships, the Wolfsberg Group (Wolfsberg), published its new Correspondent Banking Due Diligence Questionnaire (CBDDQ) in February 2018, incorporating a number of important changes. The new Questionnaireis not only four times as long as its 2014 predecessor, containing 110 instead of 28 questions, but has also expanded its scope to specifically address due diligence issues relating to Anti-Bribery and Corruption, Counter terrorism Financing,and Sanctions exposure controls. (more…)
January 24, 2018
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com
The recently imposed Venezuelan sanctions issued by the U.S., the E.U., and Canada have placed heavy burdens on sanctions compliance programs. This has made it much more difficult for companies and financial institutions who engage in business with the troubled South American nation to stay compliant.
Not only are these new sanctions on Venezuela detailed, multilateral, multi-faceted, and yet to be properly defined, but designated entities (or those businesses connected to them) are not always easily identifiable.
Many compliance suites are having trouble navigating these muddy waters.
January 8, 2018
Since the implementation of the Joint Comprehensive Plan of Action, or JCPOA, in early 2016, the international community’s plan to slowly ease sanctions against Iran has led to banks and financial institutions becoming increasingly unsure about which transactions are allowed and which are still too risky to undertake. As such, compliance officers and other professionals have had to navigate extremely treacherous waters. (more…)
Between a rock and a hard place: How to ensure sanction compliance when operating a facility in a sanctions-targeted country
June 13, 2017
By Simon Hirsbrunner and Alice Lauterjung
The recently reported resignation of cement manufacturer LafargeHolcim’s CEO has thrown a spotlight on the risks of operating commercial activities in countries targeted by economic sanctions. Without drawing any conclusions on the legal qualification of LafargeHolcim’s conduct in the specific circumstances, the following provides an overview of the principal issues at stake in this case. (more…)
March 14, 2017
On March 14, the Turkish government has announced diplomatic sanctions against the Netherlands. The sanctions, which suspend "high-level relations and all planned meetings "with the Netherlands, are the result of an intensifying diplomatic dispute between the two countries. The sanctions also include: a cancellation of permission for diplomatic flights by Dutch officials as well as a ban on the Dutch ambassador entering Ankara, until the Dutch government adheres to Turkish demands. (more…)