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ReadersSpeak

More on sanctions

fter we published "Sanctions compliance
in payment processing" by Adam Atlas
in our March 13, 2023, issue, we received
A word from the Paul, Weiss law firm of their
new report co-authored by Jessica S. Carey, co-chair
of the firm's litigation department, and Roberto J.
Gonzalez, a former Obama administration official at
the U.S. Department of the Treasury and the Consumer
Financial Protection Bureau.

The report discusses economic sanctions and anti-mon-
ey laundering enforcement by the United States in the
past year. It covers regulatory and enforcement actions
from Treasury's Office of Foreign Assets Control and
Financial Crimes Enforcement network; the Justice De-
partment; federal banking agencies; the SEC and FINRA;
New York's Dept. of Financial Services; virtual currency
regulators; and the plenary Financial Action Task Force.

Report highlights include:
• Russia: "A quasi-comprehensively sanctioned ju-
risdiction"—Leading the report and dominating
a year of broad-based national and international
regulatory action is the U.S. government's deploy-
ment of far-reaching sanctions that "have increas-
ingly made Russia effectively a quasi-comprehen-
sively sanctioned jurisdiction," researchers noted.
• A wide sweep of rulemaking and sixfold in-
crease in penalties and seizures—The report also
surveys sanctions and export controls against Chi-
na; placement of the Nicaraguan state-owned gold
company ENIMINAS on the Specially Designated
Nationals (SDN) list; some loosening of sanctions
against Venezuela; and the placement of two cryp-
tocurrency mixers on the SDN list.
• Advice beyond boilerplate—Also noteworthy are
the report's recommendations to clients, which
go far beyond routine, pro forma generalizations.
They include: follow Russian money; watch ex-
panding China-related risks; keep in mind the
long arm of U.S. law; remember that software is
not enough; be virtuous with virtual currency;
and do due diligence with banks—remember Dan-
ske Bank, which became embroiled in a large mon-
ey-laundering scandal through its Estonia branch.

Here's a link to the report: www.paulweiss.com/practices/
litigation/economic-sanctions-aml/publications/economic-
sanctions-and-anti-money-laundering-developments-2022-
year-in-review?id=46173.
AML and sanctions enforcement
How have AML and sanctions enforcement affected
your business practices? Tell us at greensheet@greensheet.
com, where we'll also welcome your questions and com-
ments on compelling issues and trends in payments.
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