On October 8, 2024, the EU Council adopted a new sanctions program against Russia in response to its “destabilizing” actions outside its territory. The Official Journal of the EU published EU Council Regulation No. 2024/2642 and Decision No. 2024/2643, which outline restrictions under the new sanction mechanism. The grounds for imposing blocking sanctions are detailed […]
On September 24, 2024, the G7 countries released new joint guidelines for the industrial sector. This document is crucial in helping businesses identify risks associated with circumventing export restrictions targeted at Russia’s defense industry. The goal of the guidance is to protect common high-priority list items from misappropriation, prevent reputational harm, and mitigate liability risk, […]
An OFAC (Office of Foreign Assets Control) license is required for individuals or entities planning to engage in transactions with individuals or entities subject to U.S. sanctions. This applies to both U.S. and foreign companies and persons, as long as their activities fall under U.S. jurisdiction. When is an OFAC License Required? It’s required when: […]
The EU has updated best practices on sanctions and, in particular, clarified the definition of control The EU has clarified the ownership criterion as follows: ownership of a company occurs if the sanctioned person owns 50% or more of the capital. The previous version of the EU Best Practices referred to ownership of more than […]
On 1 July, the U.S. Department of Commerce's Bureau of Industry and Security published a new compendium on criminal and administrative export control enforcement actions. This document is an important resource for all members of the export community.
It is important for compliance officers to keep up to date with the latest regulatory publications, in particular in the fight against money laundering and financial crime. For example, last week the European Union published a valuable document providing a list of public officials (politically exposed persons or PEPs) of Member States and EU institutions.
On June 29, 2024, the EU Council has introduced additional restrictive measures against Belarus.
Main points:
1. A ban is introduced on the supply of dual-use goods and technologies, luxury goods, and maritime navigation technologies.
2. Import of gold, diamonds, helium, coal and crude oil from Belarus is prohibited.
3. Prohibition on the provision of auditing, consulting, architectural, engineering, marketing and advertising services....
Refusing to onboard a customer can take place at different points in the customer cycle. The company may choose to not accept a new customer because after conducting customer due diligence, you discover the customer is outside of your organization’s risk appetite. Or the customer might have raised enough red flags for financial crime or for violation or circumvention of sanctions
In order to reinforce the sanctions against Russia and to prevent circumvention of the export bans, a requirement as part of the twelfth sanctions package adopted on 18 December 2023, namely Annex I to Council Regulation (EU) No 258/2012, entered into force on 20 March 2024.12.Article 12(g) requires and obliges EU exporters to contractually prohibit the re-export of certain goods to or for use in Russia when exporting, selling, supplying or transferring those goods and technology to third countries ...
What will be the sanctions policy towards Russia in 2024? This can be seen from the key decisions on sanctions already built into the current sanctions policy.
Expect to see an expansion of economic and trade sanctions, an improvement in the mechanisms for confiscating Russian assets, and more systematic attempts to force third-country companies to refuse to cooperate with Russia, in particular in the areas of industrial supplies and technological cooperation. These three areas constitute the basic scenarios for the 2024 sanctions against Russia.
Know Your Customer (KYC) is an important process for companies in a variety of industries, including outsourced accounting, real estate and legal services. It helps companies verify the identity of their customers and assess potential risks. However, there are common mistakes that can hinder the effectiveness of the customer due diligence process. In this blog post, we will look at five common mistakes to avoid when conducting customer due diligence.
The inclusion or re-inclusion of natural or legal persons in the EU sanctions measures may be challenged before the Court of Justice of the European Union under Article 263 of the Treaty on the Functioning of the European Union (TFEU).
Looking for an answer to how to set up an Internal control system (ICS) for the implementation of the AML/CFT Law on your own? Read the answer in our new blog post. But before answering the question "how?", let's first try to answer the questions "why do you need to set up an ICS in the first place?" and "what is an ICS?
Control is a critical and complex management function capable of preventing conflicts with the external and internal environment. All possible changes (internal or external) should be identified in advance and certain steps should be taken to minimize their impact on the business.
Every entrepreneur registered in Latvia who carries out economic activity or provides professional services regulated by the AML/CFT Law is already aware of a set of specific and mandatory actions that must be followed before providing a service or during a business relationship.