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.

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.

Russian Use of Crypto for Sanctions Evasion on the Rise

Experts agree there isn't enough liquidity in the virtual assets space to enable largescale sanctions evasion by Moscow, but sanctioned individuals and entities have used virtual currencies—most notably Tether—to access the global financial system and pay for restricted goods and technologies. Explore recent designations, how cryptocurrencies and other virtual assets are being leveraged to facilitate evasion as well as risk mitigation strategies for financial institutions in our latest article.

Fake News vs. Real News – The Importance of Media in Due Diligence

We exist in an age when mass media outlets are criticized for bias and manipulation, and when foreign disinformation efforts further erode trust in traditional journalism. Confidence in media reports not just as a compliance tool, but also as reliable news sources is likely at near record lows as well. However, adverse media reports are a critical compliance tool that can serve as a springboard for more extensive due diligence research and can help identify potential indicators of sanctions evasion and other financial crimes.

Counterproliferation Finance Detection and Deterrence – What Can Financial Institutions Do?

The U.S. Treasury recently identified proliferation networks operating on behalf of Russia, North Korea, China, Iran, Syria, and Pakistan as threats to U.S. national security. These networks exploited the U.S. financial system to finance the proliferation of weapons of mass destruction (WMD), including financing to procure WMD components and raising revenues to support efforts by these state actors to advance their WMD activities.

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

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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.