On 8th December, HM Treasury issued a Notice notifying changes to its Libya sanctions regime following the publication of Commission Implementing Regulation (EU) No 2017/2260, amending the details relating to the vessel “Capricorn”.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/665967/Libya_2017_2260.pdf
On 7th December EU Council Decision 2017/2265/CFSP announced amendment of the details for the vessel “Capricorn”, which is listed pursuant to UN SCR 1970.
CMS von Erlach Poncet AG of Switzerland has published an article about what has happened following the evaluation report (published December 2016) and referring to the Swiss Financial Markets Supervisory Authority (FINMA) publishing in September a draft amendment to its Anti-money Laundering Ordinance. Switzerland is in a follow-up process and must report to the FATF in February 2018 regarding the progress made. The article summarises the recommendations made in the report and the proposed changes to Swiss law and procedures.
In the US, a case highlights the risks of over-relying on simple screening software. Pilot Air Freight has suffered a $175,000 penalty ($75,000 suspended) for aiding and abetting attempted unlicensed export by a customer to IKAN Engineering Services (which is on the BIS Entity List). The company had multiple interfaces for customers’ shipping data and one, the main interface, was linked to proprietary screening software that would screen recipients against the Entity List and other relevant lists. However, the other interface allowed customers to enter shipment data, but this was not automatically linked to the screening software. So, in this case, the shipment was not flagged, and was then stopped by US Customs in Long Beach. It does not seem that Pilot Air Freight knew of the problem with their software, and the shipper would not have known either.
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