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.

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.

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

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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. 

Binging Griselda? Let’s Talk Drug Trafficking Sanctions

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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

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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.