It’s useful to remember that sanctions are part of foreign policy, and not just a way of separating bad guys from their money… The EU today just changed naval commanders as part of Project Atalanta, which involves the EU Naval Force stationed off of Somalia. It’s been in place since […]
So, how do we actually match our data to the watchlist data? There are two components to this, really: the mechanism by which we match, and what we actually match against. The matching mechanism is, ultimately, boiled down to some flavor of text search and matching technology. In broad strokes, […]
Today’s OFAC release adds a single name – Michel Samaha (also Mishal Fuad Samaha and Saadah al-Naib Mishal Fuad) to both the Terrorism and Lebanon sanctions programs. The Lebanese sanctions program is an interesting one, as it’s not a country-level program. It’s aimed at those who “undermine the sovereignty of […]
I’ve added links to the Swiss sanctions programs. Each of these pages has links to the consolidated list for the particular program, as well as delta files in PDF, MS Word and XML formats. The program descriptions are in German, so you’ll need a translation tool.
SECO, the Swiss regulatory arm for sanctions, issued two sanctions updates this morning. The first adds 3 names to its Al-Qaida/Taliban sanctions list, as well as removing 12 names and modifying 9 listings. The second release announces the addition of more information to the listings for 198 persons and 2 […]
So, Bank of Tokyo Mitsubishi UFJ Ltd’s settlement with OFAC mentioned that they entered into a tolling agreement with OFAC as part of the deal. In fact, most, if not all of the settlements I’ve reviewed involved a tolling agreement. Being a non-lawyer, I’ve always wondered what that is… so […]
Canadian regulators have taken 2 recent steps in enhancing their sanctions enacted against Syria & Iran under the Special Economic Measures Act (SEMA): On November 28th, the Governor in Council added 10 individuals and 3 entities, and removed 2 individuals and 1 entity from the SEMA Syria Regulations. On December […]
Today’s OFAC update (it’s been a busy week) has a bunch of new individuals and entities (OFAC calls anything that isn’t an individual an “entity”), all tied to both Iran and the Non-Profiliferation of Weapons of Mass Destruction (NPWMD) sanctions. Is it really worthwhile to give both designations? If the […]
So, if you keep track of OFAC’s enforcement actions, when a really big fish gets caught with a lot of overt action to skirt sanctions regulations, there is often a significant amount of publicity around the settlement agreement and civil penalties. Just look at the descriptions of the items on […]
OFAC made changes to the SDNs designated under its Counter Narcotics and Kingpin programs. Interestingly, in addition to a small number of new listings and changes, a large number of individuals and organizations were removed from the list. It would be instructive to understand why listings are removed from the […]
