Anti-Money Laundering
Export Control Limitations
I don’t spend much time dealing with export regulations. It’s kind of hard to ship a commercial office building oversees. The Bureau of Industry and Security (BIS) is responsible for implementing and enforcing the Export Administration Regulations (EAR), which regulate the export and reexport of most commercial items. Other agencies regulate more specialized exports. If… » Read More
New Anti-Money Laundering Guidance
Money Laundering is bad and financial institutions need to have internal controls policies, procedures and processes to identify higher-risk accounts and monitor the activity. At the core of an anti-money laundering program is that an institution must know its customers and the risks presented by its customers. The program becomes more difficult when the customer… » Read More
FinCEN and Address Confidentiality Programs
How do you open a bank account when you are hiding from domestic violence? The rules implementing the Bank Secrecy Act require a financial institution to implement a Customer Identification Program that includes procedures that enable it to form a reasonable belief that it knows the true identity of its customers. The rules also require… » Read More
Credit Suisse Settles OFAC Charges for $536 million
The Credit Suisse Group has reached a settlement with U.S. authorities related to U.S. dollar payments involving parties subject to U.S. sanctions. The $536 million global settlement with Credit Suisse represents by far the largest sanctions settlement in the history of US Treasury’s Office of Foreign Assets Control. The settlement arises out of Credit Suisse’s… » Read More
Amendment to the Global Terrorism Sanctions Regulations
The Office of Foreign Assets Control (OFAC) amended the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 to define the term “financial, material, or technological support,” as used in sanction regulations. Section 594.201(a)(4)(i) of the regulations implements section 1(d)(i) of Executive Order 13224, as amended, by blocking the U.S. property of persons who assist in,… » Read More
Real Estate and OFAC Compliance
The tale of 650 Fifth Avenue is one that should be closely watched by compliance professionals dealing with real estate. Last year, the Department of Justice filed a forfeiture proceeding against a 40% interest in the property held by the Assa Corporation. They recently filed a forfeiture proceeding against the other 60% held by the… » Read More
OFAC has Released its Economic Sanctions Enforcement Guidelines
The final Economic Sanctions Enforcement Guidelines were just published by the Office of Foreign Assets Control. This rule sets forth the Enforcement Guidelines that OFAC will follow in determining an appropriate enforcement response to apparent violations of the U.S. economic sanctions programs that OFAC enforces. The final rule will appear as an Appendix to the… » Read More
Money Laundering Awareness Handbook
The Organization for Economic Cooperation and Development issued a handbook that provides guidance designed to help tax examiners and tax auditors detect and deter money laundering: The Money Laundering Awareness Handbook for Tax Examiners and Their Auditors. The purpose of this handbook is to raise the awareness level of tax examiners and auditors on money… » Read More
Money Laundering with a Washing Machine
What better way to launder money than with an actual washing machine? Law enforcement in Dover, England broke up an international money laundering racket. They found £600,000 stuffed inside a washing machine that had come from the Port of Dover. Money Laundering by Simon Hughes in The… » Read More
OFAC: Are You In Compliance?
ATTUS Technologies was kind enough to host a webinar on OFAC compliance. Bradley Allen, CAMS, gave the presentation and these are my notes. The mission of Office of Foreign Assets Control is to administer and enforce economic and trade sanctions based on U.S. foreign policy and national security goals against selected targets. It really came… » Read More
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Compliance Building is published by Doug Cornelius, focusing on compliance and ethical issues for private equity real estate companies. Read more in About.
