Summary of the 2016 US Threat Assessment

The Worldwide Threat Assessment of the US Intelligence Community (the “Report“) prepared by the Director of National Intelligence on February 9, 2016, is a very interesting read from a counter-terrorism perspective, and essential reading for any bank in respect of assessing client and regional risks. Generally, the Report is dead on in respect of the [...]

New US law brands journalists and humanitarian aid workers as terrorist risk

In this story in Quartz, we explore how a new US law, HR158, the Visa Waiver Program Improvement Amendment Act 2015, will result in journalists and humanitarian aid works, and many others being branded a terrorist risk for visiting Iraq, Syria, Iran and the Sudan, and how the new law will affect the ability of [...]

The “Twitter Terrorist”

March 1, 2015, updated on May 10, 2015 Note: This is a counter-terrorism opinion based on our review of ISIS-inspired Twitter accounts for an eight month period and is intended for an audience familiar with AML/CTF.  Some Tweets included herein may be disturbing to readers who are unfamiliar with terrorism. The Twitter Terrorist & Digital Terrorism Introduction [...]

US veterans file billion dollar claims against global banks over terrorist financing and sanctions avoidance and claim that the conduct continues today

Anti-Terrorism Act filing against global banks Yesterday, symbolically the day before Remembrance Day, several plaintiffs filed suit against a number of global foreign banks based in the United States under the Anti-Terrorism Act (the “ATA“), including HSBC Holdings Plc, Barclays, Standard Chartered Bank and the Royal Bank of Scotland. The plaintiffs are seeking damages that could run [...]

PwC settles with New York bank regulator over anti-money laundering and sanctions advice

The New York Department of Financial Services (“NYDFS“) has announced that it has entered into a settlement with the advisory firm of PricewaterhouseCoopers Regulatory Advisory Services (“PwC“) over anti-money laundering and sanctions compliance advice it provided to the Bank of Tokyo Mitsubishi (“Bank of Tokyo“). PwC is suspended for two years from accepting consulting work [...]

l’Union européenne a annulé des sanctions iranien

Sanctions annulé Le tribunal de l’Union européenne a annulé hier des sanctions décidées par l’UE à l’encontre de sept établissements financiers et d’un ressortissant iranien en raison de leurs liens présumés avec le programme nucléaire controversé de Téhéran. Dans son arrêt, le tribunal qui siège à Luxembourg a estimé que l’UE “n’avait pas apporté la [...]

Review of high risk countries for money laundering

The Financial Action Task Force (“FATF“) has released its list of high risk jurisdictions for money laundering and counter terrorist financing. Reporting entities are generally required to apply enhanced due diligence when dealing with funds from jurisdictions that are high risk. The high risk countries are: Vietnam Syria Iran Kenya Ecuador Korea Ethiopia Indonesia Myanmar [...]

Another foreign bank in US settles economic sanctions violations

Another foreign bank doing business in the US has agreed to settle with the New York State Department of Financial Services (“NYDFS“) over allegations that it violated federal economic sanctions.  The Bank of Tokyo-Mitsubishi UFJ, Ltd., Japan’s largest bank, has agreed to pay US$250 million to the NYDFS to settle allegations that it provided US$100 [...]

US annual report on terrorism identifies terrorist safe havens

US Terrorism Report Released The U.S. Department of State released its annual Country Reports on Terrorism today (the “Report“), and interestingly, identified 10 key terrorist safe havens worldwide, namely Somalia, Mali, Iraq, Lebanon, Libya, Yemen, Afghanistan, Pakistan, Columbia and Venezuela. On the specific country reports, the Report identified positive steps taken by Canadian courts in [...]

Canada imposes additional sanctions on Iran essentially prohibiting all transactions

New Sanctions Against Iran The government of Canada today announced the imposition of new sanctions against Iran as a result of the lack of progress with the reduction of Iran’s nuclear program. Effective today, Canada banned all exports from and imports to Iran, and added more entities and individuals to the list of designated persons [...]