A post on the New York University School of Law’s “Compliance & Enforcement” blog notes that the US is increasingly going it alone with sanctions, in a “sharp departure” from the multilateral sanctions strategies favoured under the George W. Bush and Obama administrations, and that conflict of law presents global companies with a fast-changing and complex set of sanctions-related risks. Policymakers are turning to sanctions with increasing frequency and launching programmes that are increasingly complex, and regulatory and enforcement agencies are devoting significant resources and attention to AML. Strict distinctions among different categories of financial crime are starting to collapse, as an increasing number of sanctions programs and FinCEN advisories focus on issues such as corruption and misappropriation of assets by politically exposed persons (PEP). The useful report reviews recent trends and developments in the Bank Secrecy Act, AML and sanctions regulatory landscape in the US from 2017 to the first half of 2019.
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