Monographs/Information PapersPublished Date: 24 August 2022 Strengthening AML/CFT Practices for External Asset Managers This information paper follows from a series of anti-money laundering and countering the financing of terrorism (AML/CFT) thematic inspections and engagements conducted by MAS of selected external asset managers. It sets out MAS’ supervisory expectations for effective […]
From the resource page below, we have the following from the Central Bank of the UAE: Law: Federal Decree-Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations Cabinet Decision: Cabinet Decision No (10) of 2019 concerning the Implementing Regulation of […]
There’s much more in this document, but I thought I’d highlight Section 6 (“good practice tips): Always identify as clearly as possible the suspected benefit from criminal conduct (the ‘criminal property’) including, where possible, the amount of benefit identify the reason(s) for suspecting that property is criminal property […]
On Tuesday, OFAC issued an advisory about Iran’s Civil Aviation industry and the deceptive practices it uses. Here are some highlights – the introductory section: Subject: Deceptive Practices by Iran with respect to the Civil Aviation Industry The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is […]
From the “Risk Assessment” section of OFAC’s “A Framework for OFAC Compliance Commitments”: OFAC recommends that organizations take a risk-based approach when designing of updating an SCP. That flies in the face of everything OFAC has said over the years about sanctions being a strict liability regime. So, now imagine… […]
VI. Sanctions Screening Software or Filter Faults Many organizations conduct screening of their customers, supply chain, intermediaries, counter- parties, commercial and financial documents, and transactions in order to identify OFAC- prohibited locations, parties, or dealings. At times, organizations have failed to update their sanctions screening software to incorporate updates to […]
Root Causes of OFAC Sanctions Compliance Program Breakdowns or Deficiencies Based on Assessment of Prior OFAC Administrative Actions Since its publication of the Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A (the “Guidelines”), OFAC has finalized numerous public enforcement actions in which it identified deficiencies or weaknesses within […]
TRAINING An effective training program is an integral component of a successful SCP. The training program should be provided to all appropriate employees and personnel on a periodic basis (and at a minimum, annually) and generally should accomplish the following: (i) provide job-specific knowledge based on need; (ii) communicate the […]
TESTING AND AUDITING Audits assess the effectiveness of current processes and check for inconsistencies between these and day-to-day operations. A comprehensive and objective testing or audit function within an SCP ensures that an organization identifies program weaknesses and deficiencies, and it is the organization’s responsibility to enhance its program, including […]
INTERNAL CONTROLS An effective SCP should include internal controls, including policies and procedures, in order to identify, interdict, escalate, report (as appropriate), and keep records pertaining to activity that may be prohibited by the regulations and laws administered by OFAC. The purpose of internal controls is to outline clear expectations, […]
Mr. Watchlist 