Sanctions Top-5 for the week ending 19 February 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

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  1. The US Office of Foreign Assets Control (OFAC) announced a USD 507,375 settlement with an Atlanta-based digital currency payment processor for violations of multiple OFAC sanctions programs. According to the OFAC settlement notice, the company did not utilize IP-address information to prevent users located in comprehensively sanctioned territories from using its service. (As previously reported, OFAC settled with a California-based digital assets company in December 2020 for similar reasons.)

Comments

Double snap back! In September 2020, the State Department claimed that UN sanctions on Iran had been reimposed under UN Security Council Resolution 2231 (2015) because, well, the United States said so. Naturally, the other Security Council members weren’t having any of it. Now the State Department has reversed itself, and we can pretend the whole thing never happened.

Curious about how the UK’s post-Brexit sanctions regime is shaping up? Check out UK Sanctions Policy: A Progress Report by Emil Dall, Senior Research Fellow for RUSI’s Centre for Financial Crime & Security Studies. The report is available here.

Coming up: I’ll be presenting on OFAC compliance for non-US financial institutions in a webinar hosted by Toronto Compliance & AML Events (TCAE). Join TCAE Founder Souzan Esmaili and me on Saturday, 27 February, at 10:00 a.m. Toronto time. Registration details are here.

Did I miss something? Send me a message or comment on LinkedIn.

(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)

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Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: http://eepurl.com/cVhTXf LinkedIn at: http://goo.gl/KX1jER