2024 National Proliferation Financing Risk Assessment
The U.S. Department of the Treasury published the 2024 National Proliferation Financing Risk Assessment in February 2024 providing an in-depth analysis of the threats and vulnerabilities related to proliferation financing (PF) and highlighting key countries and non-state actors working to gain access to weapons of mass destruction (WMDs) and their components and to conventional restricted weapons and technologies.
Liberating Limits: OFAC Licenses
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) safeguards national security and helps advance U.S. foreign policy objectives by administering the U.S. sanctions regime. OFAC’s general and specific licenses serve as key mechanisms for authorizing and regulating certain transactions that would otherwise be prohibited under sanctions programs. The exceptions provided by licenses help businesses and individuals navigate international transactions without violating U.S. sanctions policies.
Golden Visas & Global Graft – How Criminal Actors Exploit Citizenship by Investment Programs
While special naturalization programs offered in certain jurisdictions to foreign investors intend to attract foreign direct investment and economic and infrastructure development, these programs can be abused by criminals who seek to launder and conceal proceeds of crime or commit new offences, including financial crimes.
Crypto Jargon Defined: Bridging the Gap Between Complexity and Comprehension
From mixers and tumblers to hot and cold wallets, the crypto space is laden with complex jargon. Explore our post in which we simplify the language of the digital economy. Ideal for enthusiasts at any level—from curious beginners to those seeking deeper insights—this guide illuminates the path to mastering the nuances of digital, virtual, and crypto assets.
Stuck and Seized – Consequences of Forced Labor
Global economies are more interconnected than ever, and human rights abuses can have a profound impact on supply chains and disrupt the flow of goods. Recent deliveries of certain luxury vehicles, such as Porsches, Audis, and Bentleys have been delayed because a small component that links those vehicles with computer networks was produced by a Chinese company linked to forced labor and surveillance of Uyghur populations in China.
Russia Sanctions Evasion Case Study: Viktor Labin
When conducting customer due diligence and enhanced due diligence, simple screening for names that may be on sanctions lists is no longer sufficient given the increasing complexity of Russia’s sanctions evasion efforts and the volatile regulatory environment because of Moscow’s aggression against Ukraine. Extra research is necessary to ensure compliance with sanctions laws and adherence with your company’s own risk policies. This research, however, can be complex, and structured analytic techniques and tools are necessary for effective due diligence.
Are Casinos Havens for Money Laundering?
A recent UN Office on Drugs and Crime (UNODC) report has found that casinos, junkets, and cryptocurrencies are exacerbating transnational organized criminal activity in East and Southeast Asia as part of the region’s underground banking and money laundering infrastructure. Although the use of casinos to launder money is not new, the proliferation of online gambling since the COVID 19 pandemic has aggravated the existing problem and has given rise to underregulated online gambling venues as more gamblers began playing from home.
Binging Griselda? Let’s Talk Drug Trafficking Sanctions
Netflix’s new series Griselda tells the story of Griselda Blanco. Known as the “Godmother of Cocaine,” Blanco trafficked cocaine from Colombia to Miami from the 1970s to the early 2000s. Despite her criminal activities, Blanco managed to evade law enforcement for many years. There were no sanctions against Blanco at the time, since the Kingpin Act, a U.S. law aimed at combating international drug trafficking and organized crime, was enacted in 1999 after Blanco’s sentencing.
Risky Russia – Government Agencies Warn Businesses of Possible Trouble
The US Departments of State, Treasury, Commerce, and Labor in late February issued a business advisory warning firms and financial institutions about the serious legal, financial, and reputational risks of doing business in Russia. According to the State Department’s assessment, Russia’s kleptocratic environment undermines fair competition and the rule of law, exposing businesses to the risk of extortion, appropriation of assets, and US law enforcement action.
Thanks to Russia, Cross-Border Sanctions Collaboration at All-Time High
Russia's unprovoked invasion and continued aggression in Ukraine has led to an unprecedented level of collaboration by sanctions stakeholders across jurisdictions, agencies, and sectors. IFI is publishing a series of blogs to highlight this increased collaboration. In this first blog, we take a look at cooperation across borders and most notably by the REPO Task Force and Price Cap Coalition.
Beyond The Hype: The True Role of Virtual Assets in Russia Sanctions Evasion
With the onset of stringent sanctions against Russia in 2022, US officials and financial analysts began to speculate about the potential for cryptocurrencies to serve as a means for evasion. But can virtual assets enables a nation's efforts to evade sanctions?
Ukraine’s War on Two Fronts – Fighting Corruption Amidst Russia’s Continued Attacks
As the second anniversary of Russia’s full-scale war of aggression in Ukraine approaches, winning on the battlefield remains the top mission objective for the Armed Forces of Ukraine, the Ukrainian people, and Ukraine’s international partners. While the full-scale invasion began two years ago, addressing systemic governmental and economic corruption has been an enduring battle for Ukraine since it gained its independence from the Soviet Union in 1991.
Pig Butchering on the Rise: When Romance Goes Wrong
What is pig butchering and how does it work? Read on to explore the global regulatory response to this rising scam, identify scam tactics and key mitigation strategies.
Exhausting Russian Resources by Sanctioning Western Software
Despite the Kremlin's attempts to reduce reliance on Western software for crucial systems, this transition is advancing slowly, presenting significant opportunities to hinder Russia's military effectiveness and economic activities. Read on for more information on the current role of Western technology and guidance for governments and companies formulating sanctions proposals.
Evading Export Controls – Russia’s Key to Success
Russia has used third-party intermediaries to evade sanctions and export controls for years and has disguised the involvement of SDNs or sanctioned entities in transactions to obscure the true identities of end users. This activity has increased since Russia’s invasion of Ukraine in 2022 due to Russia’s need for military equipment.
Bad News for Corruption in 2023, Along with Some Bright Spots
Transparency International released its annual Corruption Perceptions Index, ranking 180 countries and territories by their perceived levels of public-sector corruption. Explore the highlights within.
Human Trafficking
January is National Human Trafficking Prevention Month, and IRS-Criminal Investigations (CI) is partnering with other government agencies to highlight indicators and federal initiatives to combat this crime.
Bitcoin Breakthrough – Navigating the New Era of SEC-Approved Spot Bitcoin ETPs
The US Securities and Exchange Commission's (SEC) landmark approval of 11 Spot Bitcoin Exchange-Traded Products (ETPs) from several leading financial firms, including BlackRock, Fidelity, and Grayscale Investments, this month marks a significant shift in the regulatory landscape for virtual assets.
Real Estate in 2024 – Anticipating a Crackdown on Corruption & Fraud
Real estate in the United States has long been a popular channel for corrupt actors seeking to launder illicitly obtained funds. As part of the Biden administration’s 2021 Strategy on Countering Corruption, a long-awaited proposed rule from the Treasury Department that is slated to take effect in early 2024 will seek to address that glaring loophole in US anti-money laundering (AML) regulations.
How to Avoid Becoming an Unwitting Facilitator of Russian Sanctions Evasion
What steps can organizations take to avoid becoming unwitting suppliers of critical components and tools for the Russian military?
The Importance of a Sanctions Compliance Program – Top 5 Mitigating Measures Highlighted by OFAC in 2023
OFAC in 2023 reached settlements with 17 companies, collecting more than $1.5 billion in penalties. Mitigating factors can help reduce the severity of penalties imposed by OFAC for sanctions violations and often involve significant remedial measures and enhancements to a company’s sanctions compliance program.
A Pivotal Year for Virtual Assets – 2023 Highlights
2023 was a year of significant upheavals in the world of virtual assets, highlighting glaring vulnerabilities and the dire need for regulatory interventions. From major financial losses caused by security breaches to high-profile legal battles and settlements, 2023 was chock full of developments that almost certainly demonstrate the resilience and endurance of virtual currencies.
A Timeline of US, EU, and UK Sanctions on Russia in 2023
The United States, United Kingdom, and European Union, among others, have increased their focus on enforcement, updated sanctions lists and export controls to limit Russia’s access to sensitive technologies, and taken steps to punish illicit actors assisting Russia. Explore a list of the various sanctions imposed by the United states, EU, and UK in 2023.
Biden Signs Executive Order Targeting Foreign Banks Supporting Russia
US President Joe Biden on December 22, 2023, signed an executive order to authorize the US Treasury Department’s Office of Foreign Assets Control (OFAC) to designate foreign financial institutions that help Russia’s defense industry, as Moscow’s war against Ukraine approaches its two-year anniversary.
What Financial Institutions Can Learn from the Binance Settlement
Explore lessons learned from the recent Binance settlement including risk mitigation strategies for banks and other financial institutions.
Binance Settles with Regulators
Binance, the world’s largest cryptocurrency exchange, on November 21st pleaded guilty and agreed to pay more than $4.3 billion to resolve the US Justice Department’s investigation into its violations of the Bank..
Cyber-Enabled Fraud
Cyber-enabled fraud (CEF) is growing, especially with increasing digitalization across the globe.
Technological advances have enabled cyber criminals to develop and increase the scale,
scope, and speed of their illicit activities.
Terrorist Use of Crowdfunding
The nature of crowdfunding, the use of new technologies, and the possible anonymity afforded by crowdfunding platforms can make them attractive as relatively quick and simply means to obtain donations from across the world.
Partial Sanctions Relief for Venezuela
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued six general licenses authorizing categories of transactions that were previously prohibited under the U.S. sanctions program against Venezuela.
Best Practices for the Maritime Oil Industry to Detect Restricted Trade in Russian Oil
Price Cap Coalition partners have published an Advisory following reports that Russia has been evading the $60 per barrel price cap that was imposed by the Coalition last year. The Advisory provides some best practices and recommendations to the maritime oil industry to help stakeholders reduce their exposure to risks of Russian oil cap evasion by detecting restricted trade in Russian oil.
MiCAR Defined – The EU’s Blueprint for Crypto Regulation
The Markets in Crypto-Assets Regulation (MiCAR) went into effect on June 29, 2023, and will be fully applied by December 30, 2024.
Domestic Terrorism – Understanding the Threat and How Banks Can Counter It
Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical ideologies. In response to these troubling developments, our government has stepped up law enforcement, intelligence attention, and resources to combat these threats.