In the previous post, we laid out how firms use repeated patterns in their data and/or patterns in the matched watchlist listing to ignore matches. The upside of those strategies is that the risk, if any, is very contained if not totally eliminated. The downside is that you tend to […]
Two small sets of updates by OFAC today: Two organizations (M23 and Forces Democratiques de Liberation du Rwanda) were added to the DRC (Democratic Republic of the Congo) Sanctions program (and all their aliases, of course) Jeanine Speckman, a UK citizen, and Euromac European Manufacturer Center SRL, an Italian entity, […]
When we screen data, we match data patterns we know to be non-matches. If they occur frequently enough, we can choose to ignore that pattern going forward. In general, there are two generic types of false positive reduction (FPR) strategies: whitelisting, and rules-based processing. Whitelisting generally means that a particular […]
OFAC publishes a list of authorized air, travel and payment (they’re fancy – they call them “remittance forwarding”) service providers that are permitted to provide these services to Cuba. So, not exactly a General License, but not a specific license, either. The list was updated today. Link: List of Authorized […]
Just a quick note: OFAC has a page that lists each enforcement action and civil penalties, broken out by year. It’s a useful page, so I’ve added the link to it to the Regulatory Links page.
Ellman International has agreed to a $191,000 civil penalty for non-egregious violations of the Iran Transaction Regulations that were not voluntarily self-disclosed. The transactions were for exports of medical equipment to Iran and the hiring of an Iranian physician. The base penalty amount was $426,000 for transactions totaling $317,211, so […]
There are always more matches than we want – and experience teaches us that the ratio is not close (1000 to 1, according to BNP Paribas’ NY branch, using an exact matching methodology). We’re searching through an awful lot of hay to find needles that may or may not be […]
AUSTRAC, the Australian FIU (Financial Intelligence Unit, which is the governmental agency which investigates financial crimes) and AML/CTF regulator, has just sent out the January 2013 edition of its e-news Newsletter (which you can subscribe to here) with a whole raft of interesting information about Aussie banking regulation and enforcement. […]
A lot of this seems daunting, doesn’t it? So many possible lists, system settings to consider… and so much work to process Day 1. Seems a little nuts to me… Well, even if you’re facing down the loaded end of a C&D (cease and desist), one doesn’t have to implement […]
May your 2013 be filled with greater subject matter expertise, more skilled, productive and knowledgable staff at all levels, and (especially) fewer regulatory inquiries. All the best from Mr. Watchlist – thanks for reading!