EWRA: ENHANCING THE ROBUSTNESS OF ENTERPRISE-WIDE RISK ASSESSMENT RE AML/CFT

The Monetary Authority of Singapore has issued an Information Paper which says that an “enterprise-wide money laundering and terrorism financing risk assessment” (EWRA) assesses a financial institution’s inherent money laundering and terrorism financing risks, the effectiveness of the control environment designed to mitigate those risks, and the need to implement additional measures to manage residual risks where necessary. The requirements and expectations pertaining to EWRA are laid out in MAS Notices and Guidelines.  The information paper sets out MAS’ supervisory expectation of effective EWRA frameworks and processes.  While the paper does not impose new regulatory obligations, it says that financial institutions should study the guidance to identify and address gaps in their EWRA frameworks and processes.  It includes case studies involving flawed EMRA methodology and good use of data.  Informed by reviews of institutions undertaken by MAS, the Paper says that an EWRA provides institutions with an overview of their risk exposure and forms the cornerstone of banks’ AML/CFT risk management.  A robust EWRA enables them to better understand their money laundering and terrorism financing risks, implement relevant policies and control procedures to effectively mitigate these risks, and optimise the allocation of AML/CFT resources.

https://media-exp1.licdn.com/dms/document/C561FAQH_fjLahnMLew/feedshare-document-pdf-analyzed/0?e=1596733200&v=beta&t=0yjUeA_Q38YNBUjWCy-tpNzlgs-U0Zyc2eKTxiFK2DQ

REPORT: HOW ARE ORGANISED CRIME GROUPS INVOLVED IN SPORTS CORRUPTION?

A news release from Europol on 5 August advised that a new report highlights the link between sports corruption and organised crime: the characteristics of criminal networks, their structure and their modus operandi. In addition, the report analyses the different types of match-fixing as the most prominent form of sports corruption monitored by Europol. Football remains the most targeted and manipulated sport by international organised crime groups, it says, and individual sports competitions like tennis with a limited number of key participants (e.g. players and/or chair umpires) are an even easier corruption target for match-fixing gangs.

https://www.europol.europa.eu/newsroom/news/how-are-organised-crime-groups-involved-in-sports-corruption

The report is at –

https://www.europol.europa.eu/publications-documents/involvement-of-organised-crime-groups-in-sports-corruption

 

UK AMENDS TERRORISM SANCTIONS ENTRY FOR QASEM SOLEIMANI

On 5 August, a Notice from HM Treasury advised that Soleimani has been removed from the Annex to EU Regulation 2580/2001/EC, but remains listed under the Terrorism and Terrorist Financing regime under the Terrorist Asset-Freezing etc. Act 2010 (TAFA).  He also remains listed under the Iran (Nuclear Proliferation) regime and continues to be subject to financial sanctions.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907110/Notice_Terrorism2_2020_1128.pdf

OFAC ADDS 1 INDIVIDUAL AND 1 ENTITY TO ZIMBABWE SANCTIONS LISTS, DELETING MANY OTHERS

On 5 August, OFAC issued a news release advising that Kudakwashe Regimond TAGWIREI, (aka Kuda TAGWIREI) and SAKUNDA HOLDINGS (aka SAKUNDA HOLDINGS PRIVATE LIMITED) had been added to its Zimbabwe sanctions lists.  At the same time a large number of persons were deleted from the lists – including the late John Bredenkamp and companies related to him.  Tagwirei is a Zimbabwean businessman with longstanding associations to the ruling party in Zimbabwe and high-level Government officials. He is said to have used his relationships to gain state contracts and receive favoured access to hard currency, including US dollars. In turn, he has provided high-priced items, such as expensive cars, to senior-level Zimbabwean government officials.

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200805.aspx

https://home.treasury.gov/news/press-releases/sm1082

ISLE OF MAN: FINANCIAL SANCTIONS GUIDANCE FOR ENTITIES AND INDIVIDUALS OPERATING WITHIN THE MARITIME SHIPPING SECTOR

Dated 30 July, this new Sanctions Notice from the Customs and Excise Division in the Isle of Man sets out to provide comprehensive guidance for businesses in the Island.  It focuses on restrictions affecting Iran, Libya and Syria and details the various methods of evasion employed, as well as some due diligence steps that can be taken.

https://www.gov.im/media/1369886/sanctions-notice-54-maritime-financial-sanctions.pdf

ISLE OF MAN CONFIRMS LIBYA, NORTH KOREA AND TERRORISM SANCTIONS UPDATES, AND ISSUES MARITIME SANCTIONS GUIDANCE

On 4 August, the Isle of Man published 4 news releases. 3 confirm amendments to 1 entry on Libyan sanctions lists, 37 entries on the North Korean sanctions lists and 20 entries on the terrorism sanctions lists.  The other news release announced the publication of new Sanctions Notice 54 providing guidance for entities and individuals operating within the maritime shipping sector.

https://www.gov.im/news/2020/aug/04/financial-sanctions-libya/

https://www.gov.im/news/2020/aug/04/financial-sanctions-democratic-peoples-republic-of-korea-north-korea/

https://www.gov.im/news/2020/aug/04/financial-sanctions-terrorism-and-terrorist-financing/

https://www.gov.im/news/2020/aug/04/maritime-sanctions-guidance/

Sanctions Notice 54 is available at –

https://www.gov.im/media/1369886/sanctions-notice-54-maritime-financial-sanctions.pdf