Bubbling along in the background, Covid-19 is still present. Up until 13 April, another 28 new cases, no new fatalities, and currently 53 active cases (up from 30 the week before), with 1 person in ICU and 21 in other wards.
18 APRIL 2024
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On 18 April, the EU announced that the FAQ had been updated, and a new consolidated version issued.
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On 18 April, Silko Compliance Systems published a recording, and the Powerpoint slides, from a recent webinar which provided an update on the changes in the FATF’s Fifth Round Mutual Evaluation Reviews methodology and what private industry can expect because of these changes. The webinar involved Elisabeth Lees from Claritas Legal in the Cayman Islands.
https://silocompliance.com/aml-grey-matters-fatf-5th-round-what-has-changed-with-elisabeth-lees
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On 18 April, the Isle of Man advised that 7 individuals and 6 entities had been added to the sanctions lists, as HM Treasury issued a Notice contained the same names.
https://www.gov.im/media/1383458/annex-to-iran-sanctions-news-release-18-april-2024.pdf
https://globalsanctions.co.uk/2024/04/uk-and-us-iran-related-designations-following-israel-attack/ https://assets.publishing.service.gov.uk/media/6620f46b651136bd0b757d96/Notice_Iran_180424.pdf
On 17 April, the Wall Street Journal reported that the Biden administration says licences will be evaluated on a case-by-case basis, as it said it would allow some US and European oil companies to carry on in Venezuela after US efforts to coax President Nicolás Maduro into democratic overhauls by lifting economic sanctions ended.
https://globalsanctions.co.uk/2024/04/us-reimposes-sanctions-on-venezuelan-oil
On 18 April, OFAC advised of amendments to 2 existing entries, involving GTS GRUPP and Georgii Semenovich POGIBLOV.
https://ofac.treasury.gov/recent-actions/20240418
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On 18 April, OFAC advised that it was targeting 16 individuals and 2 entities enabling Iran’s UAV production, including engine types that power Iran’s Shahed variant UAV. These actors work on behalf of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), its UAV production arm, Kimia Part Sivan Company (KIPAS), and other Iranian manufacturers of UAVs and UAV engines. OFAC is also designating 5 companies in multiple jurisdictions providing component materials for steel production to Iran’s Khuzestan Steel Company (KSC), one of Iran’s largest steel producers, or purchasing KSC’s finished steel products. OFAC is also sanctioning 3 subsidiaries of Iranian automaker Bahman Group, which have continued to materially support the IRGC and other entities designated pursuant to counterterrorism authorities, including Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Bahman Group itself is being concurrently designated for owning these entities.
It notes that the UK was also imposing sanctions targeting several Iranian military organizations, individuals and entities involved in Iran’s UAV and ballistic missile industries.
https://home.treasury.gov/news/press-releases/jy2270
https://ofac.treasury.gov/recent-actions/20240418
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On 18 April, FinCEN advised that it has updated its Beneficial Ownership Information FAQ to include new questions and updated information about reporting companies, beneficial ownership through trusts, and access to beneficial ownership information, among other topics.
On 18 April, FinCEN issued a Financial Trend Analysis focusing on patterns and trends identified in Bank Secrecy Act (BSA) data linked to Elder Financial Exploitation (EFE), or the illegal or improper use of an older adult’s funds, property, or assets. It found 155,415 filings over the period between 15 June 2022 and 15 June 2023 indicating roughly $27 billion in EFE-related suspicious activity.
https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation
https://www.fincen.gov/sites/default/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf
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On 17 April, the Global Sanctions blog reported that a (non-binding) Opinion from the Attorney General has said that in his view the authentication and execution of a contract of sale by a notary and the translation of communications between the notary and the seller and purchaser are not prohibited by the prohibition on legal advisory services – notwithstanding what EU FAQ say. It remains to be seen if the court follows the advice.
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