Sanctions compliance gets complicated when shipping to grey-listed UAE

An American man was convicted of falsifying export documents to conceal the fact that shipments of US commodities through the United Arab Emirates was actually bound for the Islamic Republic of Iran, in serious violations of US sanctions.

The crime occurred when the man lied to the freight forwarder, claiming the ultimate destination of the goods was the UAE, despite their being a co-conspirator in Iran who was the true recipient of the goods. 

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Unintended consequences of Russian sanctions order had created a mess for lawyers

The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2023, which came into force on 30 June and prevented UK lawyers from advising Russian companies had been criticised for “creating a problem for the UK legal services industry in the UK and beyond”, including for non-Russian companies seeking advice from UK lawyers, according to the City of London Law Society. 

This had made it harder for firms to provide sanctions advice to clients, and had forced some international businesses to turn elsewhere or proceed with no sanctions advice at all. 

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The Solicitors Regulation Authority says it is keeping up to date with emerging risks and trends

An updated anti-money laundering (AML) and terrorist financing (TF) sectoral risk assessment was just published by the Solicitors Regulation Authority (SRA) that covers proliferation financing and sanctions. 

The regulatory body, which oversees solicitors in England and Wales, also noted that firms are not allocating sufficient resources to AML work as an emerging risk, mostly due to increased economic pressures. 

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Leaked emails draw back the curtain on how Putin’s friends evaded sanctions – with some help from friends in the West

Credit: Sipa US/Alamy Stock Photo
Credit: Sipa US/Alamy Stock Photo

An investigation by a group of journalists has revealed how Russian President Vladimir Putin’s inner circle has managed to hide assets despite the imposition of international sanctions.

The investigation was triggered by an email leak that was obtained by IStories and OCCRP (Organized Crime and Corruption Reporting Project) and shared with 15 other media outlets. The leak consisted of over 50,000 documents and emails sent between 2013 and 2020.

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They want to know how your law firm handles financial sanctions  

Last month, the Solicitors Regulation Authority (SRA) released a questionnaire compelling law firms to report on their firm’s approach to financial sanctions. The survey is due on May 31.

A few of your key questions about this survey are answered here.

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It’s time to look at how your firm handles designated persons

The Government’s financial sanctions regime is continually changing. It was created with national security objectives in mind and law firms play a critical role in its implementation. So much so that the sanctions regime applies to all firms that provide legal services, a broader bucket than just those that are covered by the anti-money laundering (AML) regulations.

The Solicitors Regulation Authority (SRA) just released a new questionnaire compelling law firms to report on their firm’s approach to financial sanctions.

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The Russian invasion of Ukraine which began on 24 February 2022 has displaced millions and killed tens of thousands of people. The war has also created several overlapping crises, from refugees to food supplies and massive supply chain disruption.

The conflict has also sparked waves of new laws around the world, from sanctions to tougher economic crime compliance. The main victims of the war are of course those directly caught up in it, but businesses all around the world are experiencing the effects of this unprecedented global event which shows no sign of slowing down in the next year.

VinciWorks has created a guide that reviews the key compliance challenges and lessons which have impacted on business one year into this devastating conflict.

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Wednesday 1 March, 12:00pm (UK)

Supplier onboarding has become increasingly challenging and complex in recent years. A major factor that has contributed to this situation is the ongoing conflict in Ukraine, which has resulted in heightened security concerns and economic instability, making it more difficult for companies to manage their supply chains.

In addition to the ongoing conflict in Ukraine, new legislation and regulations have been introduced to tighten restrictions on oligarchs and their illicit gains. This has resulted in increased scrutiny of suppliers, making the onboarding process more comprehensive and time-consuming. Furthermore, new jurisdictions like Turkey and the UAE have been grey-listed by the FATF for money laundering, which has led to increased regulatory requirements and a need for more due diligence in the onboarding process. The difficult economic circumstances and supply chain challenges only add to the complexity of supplier onboarding, making it increasingly difficult for companies to manage their suppliers effectively.

Overall, these factors contribute to a more complex supplier onboarding process, requiring more time, resources, and attention. Conducting effective due diligence including sanctions screening and understanding who the supplier is and who their UBOs are is vital to preventing serious compliance failures. 

In this webinar, VinciWorks will take you through: 

  • The supplier onboarding process
  • Undertaking money laundering and sanctions checks
  • How to ensure AML compliance
  • How to assess risk levels and create a due diligence audit trail
  • What tools and resources you need for supplier onboarding
  • New regulations in the EU, UK and US to take account of when supplier onboarding

Free registration

From new ESG regulations to a crackdown on bribery, rapid fluctuations in crypto currency, changes to the regulated sector and the ongoing conflict in Europe demanding a laser-like focus on the supply chain, 2023 looks set to demand even more from compliance professionals.

We have created an in-depth guide to everything compliance in 2023. The guide covers the top ten items you can expect to see in your regulatory inbox, with tips on next steps.

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The Financial Action Task Force (FATF) held its latest plenary at the end of October 2022 and updated the list of jurisdictions under increased monitoring for money laundering and terrorist financing concerns. Jurisdictions on this list are working with the FATF to address strategic deficiencies in their regimes with regard to countering money laundering, terrorist financing, and proliferation financing. These countries have committed to work to resolve the deficiencies within the agreed timeframes. The FATF does not require enhanced due diligence measures to be applied to these jurisdictions and does not wish to cut off entire classes of customers, but calls for the application of a risk-based approach for businesses working with these jurisdictions.

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