The EU’s 6th AML Directive – The Inclusion of Non-Financial Companies in the Regulation Preventing Money Laundering

Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive.  AMLD6 has a compliance date of 3 December 2020. The Directive increased the number of predicate offense categories to twenty-two.  The newly […]

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Are Sanctions Cruel?

Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]

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Much Ado, or Mucha Don’t?

On June 16th, President Donald Trump, to much fanfare, announced he was “canceling the last administration’s completely one-sided deal with Cuba”. Despite the implication that the changes to the Cuban sanctions program made over the prior two years by the Obama Administration would be largely reversed, a closer look reveals that the changes are significantly more […]

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The Science Behind False Positive Tuning

How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system?  That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of this […]

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Evolving Iranian Sanctions: Joint Comprehensive Plan of Action (JCPOA)

As part of international efforts to prevent further development of Iran’s nuclear weapons program, on December 31 2011 the United States (US) imposed various ranges of diplomatic and legal sanctions to prevent foreign financial institutions (FFI’s) from conducting transactions with Iran through the US Department of the Treasury; Office of Foreign Assets Control (OFAC) regulations. […]

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