It would be great if #fincen would consider sharing this information with the non-financial institution sector as well, as non-banks face the same compliance risks, at least in the areas of sanctions and export controls, when it comes to KYC and CDD. It seems sometimes that the raising of compliance expectations for non-banks too often outpace the growth of assistance and resources provided to help ensure the heightened expectations are met. #sanctions #exportcontrols #compliance https://lnkd.in/gDfmwQpC
Jason Rhoades, CAMS, CFE, CCE (Cryptocurrency)’s Post
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Reason #276 why it is no longer prudent to believe that only paying attention to OFAC sanctions is enough to cover your risks.
The OFSI Annual Review 2022-23: Strengthening our Sanctions is now available in both PDF and accessible formats from our website.
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Really interesting, and potentially impactful, things going on in the UK with regards to sanctions and the idea of "control." Particularly fascinating is the information on how OFSI perceives control. I'll be keeping my eye on this one. #sanctions https://lnkd.in/eJsauVVt
UK Sanctions Law in Disarray? What You Need to Know
lexology.com
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Great opportunity to work with a great team!
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I am proud to be a part of an organization like #Intel who is working to solve some of life's biggest challenges. #ai https://lnkd.in/gUe5mtTf
Intel-Backed AI Model Helps Researchers Detect Breast Cancer with...
intel.com
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Don't let the fact that Wells Fargo is a bank lead you to believe that you don't need to pay attention to today's $100M enforcement action by OFAC and the Fed ($30M from OFAC and $67M from the Fed)! While this particular fact pattern revolves around banking operations (and is pretty convoluted), the risks that led to the apparent violations are the same whether or not you're in the financial services industry. Some key takeaways: 1. Acquisitions can present huge potential areas of liability. Even if the potential violations occurred prior to acquisition, the acquiring company is on the hook. 2. Relatedly, pre-acquisition due diligence doesn't take the place of continued monitoring and oversight. Such diligence is almost always done under strict time constraints and is usually focused on looking for glaring issues. Even if you somehow miraculously get a full picture of current compliance risks at a target, you can't confidently say that you know what's going on post-acquisition if you don't have ongoing visibility and oversight. 3. Non-compliance people are never going to be compliance experts; we wouldn't expect them to be. As such, it is critical that there be specific and clear channels for reviewing compliance concerns - and those compliance persons must be in a position to take action. 4. Once an issue is identified, you need to stop the bleeding ASAP, even if it takes longer to address the underlying causes of the issue. Regulators will not look kindly on statements like, "we knew there was an issue, but we wanted to wait and include it in a larger holistic review before taking action." These may be the key takeaways, but there are more. Take a moment and read for yourself and try not to focus on the banking-specific facts, but rather the risk themes that cross all industries. https://lnkd.in/g5ynMj_d #compliance #sanctions
20230330_wells_fargo.pdf
home.treasury.gov
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It appears that the recent statements by DOJ that it is making sanctions compliance enforcement a top priority were more than idle threats. Maybe it's time to refresh those risk assessments! https://lnkd.in/gXzYi9b4 #compliance #sanctions
Credit Suisse, UBS among banks facing US's Russia-sanctions probe -Bloomberg News
reuters.com
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OFAC, BIS, and DOJ today released an informative "compliance note" covering sanctions and export controls evasion techniques. While a lot of what they talk about has been talked about before, the use of real world examples in this publication helps sometimes nebulous risks come better into focus. https://lnkd.in/g4xkgQyB #sanctions #exportcontrols #compliance
20230302_compliance_note.pdf
home.treasury.gov
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We don't have all of the details yet, but the EU has finally agreed on additional Russia sanctions that should closely align with what was announced earlier today by the U.S., E.U., and other G-7 countries. https://lnkd.in/gBEsQGfM
EU slaps new sanctions on Russia, almost missing self-imposed deadline
euronews.com
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Personal Opinion - Intentional or not, this is the natural result of the U.S. refusal to engage meaningfully with Cuba. I'm sure Russia is more than happy to extend its sphere of influence just off the U.S. coast. https://lnkd.in/gybaPQJj #sanctions
Miami Herald
account.miamiherald.com
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