Russian ‘Mirror Trading’ Case Reveals Five Long-Running Compliance Failures at Deutsche Bank

March 9, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

On January 30, 2017, the New York State Department of Financial Services (DFS), NY’s financial watchdog, as well as the Financial Conduct Authority (FCA), financial services regulator in the UK,ordered Deutsche Bank to pay $425 million and £163 million, respectively, for violations of anti-money laundering regulations and continual, wide spread compliance failures. The so-called ‘mirror trading” scheme, involving the German lender’s Moscow, London and New York offices,resulted in $10 billion being transferred out of Russia. (more…)

Monetary Sanctions Consultation Released by UK’s OFSI Points to Stricter Sanctions Enforcement

December 19, 2016
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

Companies, individuals, and financial institutions may receive monetary penalties under civil law when breaching financial sanctions under a new proposal by the UK government that could shape the future of financial sanctions enforcement.

Calling for responses to a consultation document by January 26, 2017, the UK Office of Financial Sanctions Implementation (OFSI) has said the planned changes will allow “more flexible, effective and proportionate set of enforcement measures”. (more…)

New UK study aims to track trends in money flowing into WMD programs

October 4, 2016
By: Jonathan Brewer

Seventy five years after the first use of an atomic bomb, the proliferation of weapons of mass destruction (WMD) continues to be a threat to international peace and security. Each year, governments invest major resources in combating the quickening spread of WMD, which include nuclear weapons. Examples are the disrupting of the procurement networks, prosecuting the individuals and companies involved, and disrupting the money flow. (more…)

Sanctions: Brainteasers With Serious Consequences

By: Davina Given*

Failure to comply with financial sanctions carries serious penalties, most notably in the US, where banks have collectively paid billions of dollars in fines.  Even in the UK, a failure to comply with sanctions carries the potential for unlimited criminal and regulatory fines and/or imprisonment.  Yet financial sanctions are often difficult for most businesses to grapple with, particularly if they do not have the resources of the very largest businesses.  Political imperatives may lead to the imposition of financial sanctions in respect of existing, longstanding business.  Individual targets may change quickly and abruptly, with little fanfare.  Different countries involved in a transaction may apply slightly different financial sanctions, so that the transaction may be legal in one country but illegal in another.  Yet on top of those issues, there is a further legal difficulty: what does any particular financial sanction actually prevent? (more…)

UK ‘Brexit’ shocks the world and creates an uncertain future for European sanctions implementation

By: Anna Sayre, reporter SanctionsAlert.com 
Date: June 30, 2016

On June 23rd 2016, after 40 years of membership, the UK has voted to no longer be a member of the European Union. A 52% majority of the British population have cast a “Leave” vote, creating a momentous decision in British history that will make an indelible mark in the financial landscape of the world for years to come. The vote by the UK to leave the EU, or ‘Brexit’, has already created mounting uncertainty within the UK financial market, caused the British pound to plummet, and made big banks and other financial institutions consider a permanent move from London to much less volatile offices in Frankfurt or Dublin. (more…)

UK officially launches the Office of Financial Sanctions Implementation: the implications of Britain’s new sanctions watchdog

Date: April 5, 2016

After earlier referenced in the Summer Budget 2015, on March 31, 2016, the UK has launched the new Office of Financial Sanctions Implementation (or OFSI). This agency will replace the Asset Freezing Unit of HM Treasury, which originally took over from the Financial Sanctions Unit of the Bank of England in October 2007. The former was created in order to specifically combat terrorist financing. The new OFSI, however, is expected to have a broader scope. Although no formal mandate has been laid out for OFSI to date, it is expected to have a dual function of awareness-raising around sanctions, as well as facilitating enforcement. In the Summer Budget, the role of OFSI was described as “working closely with law enforcement” to ensure sanctions were “properly enforced”. In a statement by the UK Chancellor, George Osborne, OFSI will raise “awareness and clear guidance to promote compliance with financial sanctions… and closely with other parts of government to ensure that sanctions breaches are rapidly detected and effectively addressed.” (more…)

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