Sanctions

Explore the complexities of sanctions through nuanced perspectives and comprehensive analyses on varying sanctions topics and their global impact and implications, including global sanctions programs, case studies, and evasion tactics.

2024’s Top 10 Major Developments

Explore the highlights from our recent webinar including an overview of the current illicit finance landscape, major events in 2024 as well as noted possible future developments as the global illicit finance regime grows and evolves.

Syria Sanctions Relief

The U.S. Treasury has issued a Syria General License to provide gradual sanctions relief for the Syrian people after the regime of Bashar al-Assad was toppled in December 2024. What does this sanctions relief mean to financial institutions and other firms hoping to transact in the country?

Sanctions in 2024: Global Pressure Points in the UN, U.S., EU, and UK

In 2024, the UN, U.S., EU, and UK ramped up sanctions targeting Russia, Iran, and conflict zones, focusing on critical sectors like energy, defense, and technology. In this article, we explore these coordinated efforts aimed at weakening adversarial regimes while navigating complex compliance and humanitarian challenges.

Toward a Financial Integrity Risk Management Program

This article explores the commonalities between AML, sanctions compliance, ABC, fraud risk management, and export control compliance programs and recommends that organizations consider using a holistic financial integrity risk management and compliance framework.

The Sanctions Evasion Threat

It’s more important than ever for compliance officers to understand and recognize sanctions evasion typologies. In this article, we explore six of the most common techniques illicit actors use to evade sanctions.

The Convergence of Sanctions & AML

The convergence of sanctions and anti-money laundering efforts has significantly accelerated since Russia’s full-scale invasion of Ukraine in February 2022. FINTRAC in June 2024 released a special bulletin focusing on financial activity associated with suspected sanctions evasion. The report highlighted shared methodologies and insights to help compliance teams collaborate on best practices.

Targeting Russia’s IT Dependencies

Delve into the recent determination issued by OFAC, which imposes significant additional restrictions on the provision to Russia of IT consultancy and design services as well as IT support and cloud-based services of enterprise management and design and manufacturing software. Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.

Crypto Under the Microscope

In the fast-evolving digital assets market, compliance is not just a regulatory requirement—it's a strategic imperative. From Binance's multi-billion-dollar settlement to the dramatic collapse of FTX, recent enforcement actions have sent shockwaves through the industry, underscoring the critical need for a robust compliance system.

OFAC’s Compliance Guidance in Action

The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.

Types of Sanctions – A Vast and Varying Landscape

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In the United States, most sanctions programs combine multiple types of designations that vary across multiple dimensions. U.S. designations are constantly changing, and more individuals, entities, vessels, and aircraft are being added to OFAC’s sanctions list. Explore the five primary types of sanctions in our latest article.