FinCEN issues money laundering advisory for Iran’s use of Bitcoin and digital currencies

FinCEN has issued an advisory for Iran that specifically is targeted for digital currency exchanges, banks and foreign banks so that the latter can understand their obligations under the correspondent banking system. The advisory is interesting because it is one of first instances of an attempt to provide guidance to foreign banks in respect of the [...]

Iran using ghost supertankers to avoid sanctions law

According to this article in the Financial Times, Iran has sent a supertanker, called Happiness I, en route to Asia, carrying 2 million barrels of oil that is off-the-radar literally, in order to obfuscate that it is transporting Iranian oil to another country. When ships are off-radar, they turn off their transponders and are no [...]

Iran sues US over sanctions

The Islamic Republic of Iran is suing the US at the International Court of Justice (ICJ) over the US sanctions annouced on May 8, 2018. ICJ is the forum for the resolution of disputes among members of the Untied Nations. Iran is claiming that the sanctions of May 8, 2018, violate the Treaty of Amity entered into [...]

US to adopt national money laundering & terrorist financing strategy that includes risks from digital currencies

US President Trump signed new sanctions legislation into law on August 3, 2017, against Iran, Russia and North Korea, and at the same time, adopted a new national strategy to combat terrorist financing and money laundering. The legislation, “HR3364 – Countering America’s Adversaries Though Sanctions Act” is more than about sanctions. In large part, it’s [...]

Does privilege really prevent lawyers from reporting money laundering?

In Canada and the US, lawyers are not subject to anti-money laundering reporting obligations like they are in most other countries. One of the most frequent reasons given for this by lawyers is that to require us to report certain financial transactions to a financial intelligence unit is inconsistent with, and would undermine, legal privilege. [...]

US lists Vancouver company a “significant transnational criminal organization”

Vancouver company listed as a criminal organization  Allegations of global money laundering from Vancouver through the financial system Today, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“), designated Vancouver based PacNet and its connected companies, as a significant transnational criminal organization (“TCO“) for its role acting as an alleged money laundering [...]

Iran renews calls for the deportation of Khavari

The requested deportation of Mahmoud Reza Khavari, a former Iranian foreign national, and a Canadian citizen living in Toronto, seems to be at the centre of the arrest of a Canadian professor from Montreal, Homa Hoodfar, also an Iranian foreign national and equally a Canadian citizen, who was visiting Iran. Professor Hoodfar was arrested by [...]

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 [...]

US approves law limiting access to the US for people who visited or are from Iran, Iraq, Syria & Sudan

A “Terrorist Risk” Following the terrorist attack in San Bernadino on December 2, 2015, an 11-month-old relatively dormant bill to amend an American law to impose visa restrictions on select foreign nationals entering the US gained traction when it was rapidly enacted in the US. US Bill H.R. 158, the Visa Waiver Program Improvement Act [...]