Trusts and Company Service Providers (TCSPs) can provide an important link between financial institutions and some of their customers. TCSPs have often been used, wittingly or unwittingly, in the conduct of money laundering activities. The majority of TCSPs are established for legitimate purposes, the Financial Action Task Force’s research Shows that some TCSPs are being … Read more »
Category: 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 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 Sun Read more »