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Dec. 20, 2012: OFAC giveth, OFAC taketh away

Two releases today from OFAC: This morning, 3 individuals were added to the Transnational Criminal Organizations sanctions: 2 Kyrgyz nationals, and 1 has Georgian and Russian citizenship. This afternoon, OFAC issued a new General License (#6) for the Weapons of Mass Destruction Proliferators sanctions program. This license authorizes transactions related […]

The delicate balance of watchlist screening

Balance? What’s balance? Balance between the costs of compliance and the potential costs of non-compliance, of course. But, but, but… doesn’t OFAC sputter about its “strict liability” policy? Sure, but they also have their Enforcement Guidelines, which informs how they determine how hard to slap a firm’s wrists, if at […]

Term of the day (Canadian edition): FACFOTER

FACFOTER is Canada’s Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, which are the regulations specific to those two countries as part of the Freezing Assets of Corrupt Foreign Officials Act. These regulations are intended to freeze the assets of “former leaders and senior officials or their associates […]

DFAT & UN changes

The United Nations modified one entity sanctioned under the Al-Qaida/Taliban terrorism program today. Links: UN Security Council Committee advice Note: the DFAT notice was received as an email with no associated document – the only link was to the UN release.

Beyond Vanilla – Flavors of Matching

It’s one thing to want to match against watchlists, and it’s another to figure out all the ways your technology can miss something you want to catch (or catch something you don’t want). So, consider the following things that some screening engines do, and consider the implications for the results […]