On 31 March 2016, HM Treasury announced that the Office of Financial Sanctions Implementation (“OFSI”) had officially been established. In their announcement, HM Treasury said: “OFSI will provide a high-quality service to the private sector, working closely with law enforcement to help ensure that financial sanctions are properly understood, implemented and enforced.” Chancellor George Osborne said: […]

The inherent risk of money laundering and terrorist financing can be lower in the life insurance sector relative to some other sectors, but life companies need to be cognisant that there are products, customers and geographic regions that present a higher risk. So reads the Press Office communication just received (Tuesday 8th March 2016) from the […]

Robust sanctions compliance is of central importance to financial services businesses in Jersey, a point made all the more important by the impact of recent EU/US sanctions. Both the EU and US sanctions purport to stifle certain technology/defence and oil exploration activities benefiting Russia. The EU sanctions pursuant to Regulation (EU) No 833/2014 as amended […]

In this briefing we discuss the implementation of the landmark nuclear deal with Iran. Iran received far-reaching economic and financial sanctions relief on 16 January 2016, after meeting key nuclear commitments set out in the Joint Comprehensive Plan of Action (JCPOA) reached between the P5 + 1 (China, France, Germany, Russia, the United Kingdom, and […]

Implementation Day – the day when a range of sanctions against Iran are due to be lifted – is now thought to be imminent. The publication of further US and EU guidelines and responses to FAQs on the sanctions is also expected in the coming days. Almost six months following the signature of the Joint […]

THE HM Treasury has issued a guidance note on operating within the UK’s counter-terrorism legal framework, which includes sanctions measures. Although the guidance note is aimed at Non-Governmental Organisations (NGOs) it is relevant to other sectors. Like other guidance on sanctions and related measures previously issued by HM Treasury, the guidance note is neither applicable […]

The key compliance challenge of the modern investment bank is to convince employees that their electronic communications are being monitored. The big bank fines and scandals of the post-crisis era are about stupid e-mails and electronic chats. The conduct was vague, ambiguous, hard to prove; the proof of nefarious intent came from all the dummies […]

A – Overview The significant threats posed to the world by terrorism are reflected in the increasingly onerous obligations placed upon banks requiring, amongst other things, a high degree of scrutiny of the activity on customer accounts to avoid breaching any sanctions regime in place. A failure to take required steps can amount to a […]