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 […]
Today, the Swiss updated their sanctions against the Democratic Republic of the Congo (DRC), adding 2 individuals. Links: FINMA Press release SECO DRC Sanctions Page Data Files: PDF Changes MS Word Changes XML Changes Consolidated List (PDF)
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 […]
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.
Today, OFAC removed a relative slew of narcotics traffickers (one has to assume they are now, at worst, “ex” traffickers) from the SDN list. It’s been a busy week over at Treasury – perhaps clearing the decks before decking the halls for the Christmas holiday. Here’s today’s release – happy […]
OFAC today added 2 colonels involved in the Congo atrocities under General Ntaganda to the SDN List. These should look familiar, though – DFAT added these back on December 6th. Links: OFAC Press Release
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 […]
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 […]
Mr. Watchlist 