February 27, 2020 By: Anna Sayre, CSS, Director of Content at ACSS
On January 31, 2020, the U.K. Parliament finally cut ties from the E.U. after two years of grueling debates and discussions in Brussels, signaling a chance for Britain to break away from the E.U. sanctions that it has most dutifully applied for decades. Though itis almost certain that the U.K. will continue to apply most E.U sanctions, it is also looking likely that the U.K. will instill a new sanctions regime of its own, perhaps more closely matching that of its American cousin across the pond.
The ‘Brexit’ Effect: What the UK’s Departure from the EU Could Mean for the Global Sanctions Landscape
December 9, 2019 By: John McKendrick QC* and Alex Haines**
Over three years ago, in the June 23 Referendum, the UK voted to leave the European Union (EU). This departure from the EU, also known as ‘Brexit’, has put the world on stand-by, waiting to see what terms the UK and Europe will decide for their future divorce. One of these terms will be how to treat sanctions policy once the UK leaves.
August 05, 2019
OFAC Publishes New Framework for Compliance Commitments, Naming 5 Essential Components
On May 2, 2019, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) published a Framework for OFAC Compliance Commitments “in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with a framework on the essential components of a sanctions compliance program”. This guidance marks the first time that OFAC has provided prescriptive guidance to companies on its views of what should be included in an effective sanctions compliance program. (more…)
SanctionsAlert.com Summer Sanctions Round Up
September 5, 2018
U.S. Cracks Down on Russia with Global Magnitsky Regulations and New Sanctions
As of June 29,2018, the Global Magnitsky Sanctions Regulations (31 CFR part 583) took effect on the Federal Register. These regulations implement the Global Magnitsky Human Rights Accountability Act (or U.S. Global Magnitsky Act) as well as Executive Order 13818 of December 20, 2017.
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.