Background 1. Financial sanctions legislation requires that financial institutions freeze the accounts and other funds or economic resources of designated persons and to report their findings to the Treasury. Under the legislation the Treasury can request information you may possess for the purpose of monitoring compliance. 2. Every year the Treasury carries out a review […]

The Wolfsberg Group, an association of 13 global banks, has issued a set of frequently asked questions (FAQs) on risk assessments for money laundering, sanctions and bribery and corruption. The FAQs include: What is the purpose of a risk assessment? Whose responsibility is it to undertake a risk assessment? Should the scope of a money […]

The London office of Reed Business Information sold critical data that helped sanctioned banks funding chemical and nuclear weapons in Syria and Iran make complex international transactions. A BuzzFeed News Investigation unravels the web. The Middle East salesman had been wrestling with his conscience for more than a month when the barrel bombs broke and […]

Disclosure of suspected breach of financial sanctions in contravention of EU regulations. Breach Form Template Document

The Council of the European Union has published a revised version of its guidance on financial sanctions, “EU Best Practices for the Effective Implementation of Restrictive Measures”. The revised guidance provides some clarification of the many issues which arise in practice for both Member States and for persons and entities subject to financial sanctions or […]

Multiple jurisdictions Depending on which jurisdiction a firm is active in it may be required to comply with the requirements of multiple sanctions regimes. Some jurisdictions’ requirements may also apply without a firm having an actual presence in that jurisdiction. The UK’S Joint Money Laundering Steering Group, suggests in its guidance that “firms should take […]

IRAN SANCTIONS – PROPOSALS ANNOUNCED FOR RELAXATION OF US AND EU RESTRICTIONS On April 2, 2015 representatives from the US, EU and Iran announced that, following extensive negotiations, the “P5+1” (China, France, Germany, Russia, the UK and the US) and Iran had agreed parameters (the “Parameters”) for a joint comprehensive plan of action regarding Iran’s […]

On April 2, 2015 representatives from the US, EU and Iran announced that, following extensive negotiations, the “P5+1” (China, France, Germany, Russia, the UK and the US) and Iran had agreed parameters (the “Parameters”) for a joint comprehensive plan of action regarding Iran’s nuclear program (the “JCPOA”). Whilst the final provisions of the JCPOA have […]