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Due Diligence

Articles

Do Cryptocurrencies Pose a Sanctions Risk?

October 04, 2019 By: Natasha Bright, ACSS Reporter

The virtual currency sector has exploded in the last few years. What began as one cryptocurrency in 2009 – Bitcoin – has ballooned into a market of more than 2200 in circulation as of July 2019. Even FaceBookcurrently has plans to roll out a new cryptocurrency – the Libra. The company has announced its target launch of the coin in the first half of 2020. Yet, financial institutions, regulatory bodies, and governments around the globe remain apprehensive about engaging with this sector due to its inherent risk. (more…)

Wake Up To Sanctions | Second Quarter 2019 – Summer Edition Sanctions Round Up

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…)

US Treasury Requests Further Funds Increase For Sanctions, Terrorism, and OFAC IT Infrastructure

May 2, 2019 By: Anna Sayre, Head of Legal Content, ACSS

Regulators at the U.S. Treasury have signalled their top priorities for the year, and it doesn’t look good for sanctions violators. The Treasury’s Office of Terrorism and Financial Intelligence (TFI)’s new budget proposal calls for a substantial increase in funds to both fight terror and enhance sanctions policy enforcement.

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Wake Up To Sanctions

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.

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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…)

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