The Green Sheet Online Edition

March 27, 2023 • Issue 23:03:02

Readers Speak: More on sanctions

After we published "Sanctions compliance in payment processing" by Adam Atlas in our March 13, 2023, issue, we received 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-money 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 Department; 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 jurisdiction"—Leading the report and dominating a year of broad-based national and international regulatory action is the U.S. government's deployment of far-reaching sanctions that "have increasingly made Russia effectively a quasi-comprehensively sanctioned jurisdiction," researchers noted.
• A wide sweep of rulemaking and sixfold increase in penalties and seizures—The report also surveys sanctions and export controls against China; 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 cryptocurrency 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 expanding 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 Danske Bank, which became embroiled in a large money-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 comments on compelling issues and trends in payments.

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