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Insight

Sanctions

With the US out of the Iran deal, the EU considers ‘Blocking Regulation’


In 2015, an agreement, known as the Joint Comprehensive Plan of Action (JCPOA), was drawn up in which Iran agreed to curtail its nuclear activities in return for the lifting of UN, US and EU sanctions.....More

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Money Laundering and North Korea


I read an article recently that highlighted how North Korea is using Hong Kong to launder their criminal proceeds. The article described the use of shell companies established in the region that provide the Democratic People’s Republic of Korea (the official name of North Korea) with access to the global financial system. Severe international sanctions are in place to restrict this access to North Korea, so any advantage they can gain is really important for them to maintain the best access they can.

How Iran circumvented US sanctions for 20 years through real estate in Manhattan


A decade-long battle between the United States government and the owners of a New York skyscraper was concluded last month when a US jury agreed with the government’s assertion that the Alavi Foundation, the majority owners, were guilty of money laundering and violating sanctions on Iran.....More

Designated by D.C.: How US Sanctions Combat Foreign Corruption


The use of sanctions as an international means of affecting change has grown exponentially in recent times. As countries become less and less keen to use military force, the world has turned to sanctions implementation as a means of impacting international change, both politically and socially.

Top Ten FCPA Fines


As this is Anti-Corruption week, I thought it would be good to take a look at the top ten fines handed down to companies under the Foreign Corrupt Practices Act (FCPA).....More

Implementation Day presents a shifting sanctions landscape


“Implementation Day” – the lifting of sanctions following Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) – came around more swiftly than some had anticipated at the time that the JCPOA was initially agreed. Anyone not expecting compliance to be achieved so rapidly will be feeling the pressure to get fully up to speed with this new landscape.

When enforcing the tone from the top really appears to mean low hanging fruit


It is with some disquiet and unease that I have been reflecting on the finer points of the recent enforcement action that was published earlier this month by the FCA concerning the affairs of the Bank of Beirut and in particular the personal sanction announced of the Compliance Officer and Internal Auditor, and I felt compelled to put pen to paper.....More

Guilty pleas: still too big to jail?


Recent reports suggest that BNP Paribas may be facing fines potentially in excess of US $5bn for sanctions violations and, moreover, that the bank is being pressed to plead guilty to criminal charges as part of any resolution.

After the hype fades, follow through. You have been warned: bribery & corruption


So the UK FSA has published their Thematic Review of Anti-Bribery and Corruption (ABC). The lesson is clear. After a new law is enacted or a financial crime theme becomes the focus of regulators due to a scandal, there is a huge response and hype. When the dust settles firms must ensure that control frameworks are properly implemented, and they finish the job. We know the regulators will be watching.....More

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