Incisive commentary from leading voices in the world of compliance

12 Sep 2017
Published in Article

US sanctions: you’re on your own

A call to OFAC’s Hotline revealed that no designations would be forthcoming, and that it was up to U.S. persons to identify all elements of the government (plus 50 Percent Rule holdings) and their securities issues. There is no longer any de minimus way for even the smallest firms or those with minimal overseas exposure to maintain any level of compliance through reliance on OFAC’s published lists.

05 Sep 2017
Published in Article

Donald Trump’s dangerous attitude to transparency in the extractive industries sector

One of the Trump administration’s first legislative acts – and thus far one of its few successful ones in concert with a Republican-majority Congress – was to abolish a pending Security and Exchange Commission rule that would have forced oil companies to reveal details of any payments to foreign governments that relate to fossil fuel production.

31 Aug 2017
Published in Article

Susan Grossey: Near-o tolerance—the perils of de-risking

I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose of entire classes of customer”.  In the past year, dire warning about the dangers of dealing with money service business and with charities have resulted in these businesses finding themselves unable to open bank accounts or send wire transfers.