OFAC – IRAN SANCTIONS: NEW GENERAL LICENSE, UPDATED FAQ, ADDITIONAL INDIVIDUALS AND ENTITIES, PLUS 2 VESSELS, ADDED TO LISTS WITH OTHERS AMENDED

On 26 October, OFAC advised various changes to its Iran sanctions regime –

  1. New General License 8A – Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company;
  2. Several FAQ amended as a consequence;
  3. 8 individuals added to SDN List;
  4. 11 entities connected to the oil or shipping sectors added to SDN List;
  5. 2 crude oil sea tankers added to SDN Lists;
  6. Amendments made to existing entries for ABADAN OIL REFINING COMPANY, NATIONAL IRANIAN OIL COMPANY and NATIONAL IRANIAN TANKER COMPANY.

The additional sanctions measures target the Iranian oil and shipping industries and key associates, including those involved in gasoline supplies to Venezuela.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201026_33

https://home.treasury.gov/news/press-releases/sm1165

https://home.treasury.gov/system/files/126/iran_gl8a.pdf

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OFAC – AMENDMENT OF CUBAN SANCTIONS REGULATIONS AND UPDATED FAQ

On 26 October, OFAC advised that a new Rule will be published in the Federal Register on 27 October, and will be effective 30 days later on 26 November.  It is also updated several related FAQ.  The idea behind the changes is to remove Cuba’s military-run entities from the remittance process.  Specifically, OFAC is amending the regulations to remove from the scope of certain remittance-related general authorizations any transactions relating to the collection, forwarding, or receipt of remittances involving entities or sub-entities identified on the State Department’s Cuba Restricted List (CRL). 

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201026

https://home.treasury.gov/news/press-releases/sm1164

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WHAT ART MARKET PARTICIPANTS NEED TO KNOW ABOUT CHANGES TO AML REGULATIONS

On 26 October, an article from Mishcon de Reya says that a 5-month extension has been granted to the time period that newly regulated art market participants have to register with HMRC for AML purposes – the deadline for registration is now 10 June 2021, instead of 10 January.  If they fails to register by 10 June, they must not carry on the defined activities within the scope of the regulations.  The new regulations will affect many working directly within the art market, such as high value dealers and auction houses, and potentially other parties such as agents, intermediaries and some artists.

https://www.mishcon.com/news/art-market-participants-what-you-need-to-know-about-changes-to-anti-money-laundering-regulations

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OUTCOMES OF FATF PLENARY

On 23 October, FATF published a series of documents following the FATF Plenary of 21-23 October –

http://www.fatf-gafi.org/publications/fatfgeneral/documents/outcomes-fatf-plenary-october-2020.html

FATF RECOMMEDATIONS UPDATED

Revision of Recommendation 2 and a new Interpretive Note to Recommendation 2.

JURISDICTIONS UNDER INCREASED MONITORING

FATF continues to identify additional jurisdictions, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. A number of jurisdictions have not yet been reviewed by the FATF and FATF-style regional bodies.

http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-october-2020.html

PUBLIC STATEMENT ON COUNTER PROLIFERATION FINANCING

FATF has  adopted amendments to Recommendations 1 and 2 and their Interpretive Notes that require countries and the private sector to identify, and assess the risks of potential breaches, non-implementation or evasion of the targeted financial sanctions related to proliferation financing, as contained in FATF Recommendation 7, and to take action to mitigate these risks, as well as to enhance domestic co-ordination.

http://www.fatf-gafi.org/publications/financingofproliferation/documents/statement-proliferation-financing-2020.html

HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION

The list of high-risk jurisdictions has not changed since February, i.e. North Korea and Iran.

http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/call-for-action-october-2020.html

THE IMPORTANCE OF ALLOCATING SUFFICIENT RESOURCES TO AML/CFT REGIMES DURING THE COVID-19 PANDEMIC

Statement by the FATF President.

http://www.fatf-gafi.org/publications/fatfgeneral/documents/covid-19-impact-oct-2020.html

FATF PRESIDENT’S REMARKS TO G20 ANTI-CORRUPTION MINISTERIAL

The FATF President calls for an investment in law enforcement,to plug the holes in the availability of beneficial ownership information, and an increase our oversight of the non-financial sectors, thegatekeepers to the financial system – such as lawyers, accountants and company service providers – need to be inside the regulatory tent.

http://www.fatf-gafi.org/publications/corruption/documents/g20-anti-corruption-2020.html

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GAS FIELDS AND TENSIONS IN THE EASTERN MEDITERRANEAN

On 26 October, EurActiv said that the discovery in recent years of huge natural gas reserves in the eastern Mediterranean has whetted the appetite of nearby countries but exacerbated geopolitical tensions between Turkey and its neighbours; and relations have been strained in recent months following Turkish exploration and drilling operations in waters claimed by both Cyprus and Greece.  Cyprus, which has aspirations of becoming a major energy player in the region, has a key exclusive economic zone (EEZ), divided into 12 blocks and potentially rich in gas.

https://www.euractiv.com/section/energy-environment/news/gas-fields-and-tensions-in-the-eastern-mediterranean/

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IRAQ EMERGES AS NEW FRONT FOR ENFORCEMENT OF IRAN OIL SANCTIONS

On 23 October, the Wall Street Journal reported that Persian Gulf waters off Iraq have become a new, important waypoint for Iranian oil smugglers looking to avoid US sanctions, according to US officials, who expressed frustration that Baghdad and other allies aren’t acting more aggressively to enforce curbs on commerce with Tehran.  Iranian tankers now regularly transfer crude to other ships just miles offshore the major Iraqi port of Al Faw, according to the officials. The oil is then mixed with cargoes from other places to disguise its origin, and it eventually ends up on sale in world markets.

https://www.wsj.com/articles/iraq-emerges-as-new-front-for-enforcement-of-iran-oil-sanctions-11603445401

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