Rapaport’s Post

2023 was another record year for U.S. #sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Read MoFo’s “OFAC Year in Review” for a refresher on OFAC’s major activities and programmatic updates from 2023: https://bit.ly/3T3h6xF #OFAC

U.S. Department of Treasury declared actions against the financial networks helping Houthis. Check out this article 👉 #USDepartmentofTreasury #Maritime #MarineInsight #Merchantnavy #Merchantmarine #MerchantnavyShips

As expected, the Financial Action Task Force (FATF) announced it will seek "further dialogue with the relevant bodies and experts in both the public and private sectors" before finalizing changes to Recommendation 16 covering payment transparency--referred to as the Travel Rule in the U.S. The FATF working group overseeing revisions to Recommendation 16 has demonstrated an impressive command of the weighty issues involved. They should be commended for seeking more input to ensure the global financial system can provide efficient payments within an effective compliance framework that protects against illicit finance. https://lnkd.in/e68n6udb

The Treasury Department's proposed rule changes for CFIUS will impact foreign investments quite a lot. Economic developers must be prepared for expanded information requirements, longer response times and increased penalties for non-compliance. Aimed at improving national security, these changes could complicate transactions in the industrial real estate domain. Read more at: https://buff.ly/3VJ4mgH #EconomicDevelopment #IndustrialRealEstate #CFIUS #Regulations #NationalSecurity

When you hear the term ‘debanking’, you might think of the high-profile case last year involving Nigel Farage. Back then, there was a lot of discussion surrounding whether it’s appropriate to treat ‘domestic’ PEPs as less risky, and how to separate political belief from risk indicators. But debanking isn’t just an issue that affects politicians – this article from RUSI provides a good explanation of how current sanctions could cause debanking and potential consequences of this for the global economy. Interestingly, the overall message isn’t too dissimilar to the conversation that was sparked last year. Although on a totally different scale, it’s still a matter of how much politics can be an indicator of risk and the difficulty of balancing risk-based decisions with ensuring no one is denied services unjustly. Clearly, this is a worldwide, complex issue. That said, I can’t help but think that placing an increased focus for financial services firms on gaining a deep understanding of risk, rather than favouring a quick decision on whether someone might be too risky to onboard, could be part of a solution. Here’s the article if you’d like to read it too: https://hubs.li/Q02JbFH40 #Sanctions #Debanking #FinancialIntelligence

Financial Intelligence Units (FIUs) are specialized government bodies created by countries to centralize the collection of suspicious activity reports related to financial crimes, such as money laundering and terrorism financing. FIUs analyze these reports and share their findings with relevant government agencies to aid in the enforcement of financial laws and the detection of criminal activities. FIUs became more prominent in the public sector during the early 1990s as the need for more coordinated efforts to combat financial crime grew. In 2004, the International Monetary Fund (IMF) published a report titled "Financial Intelligence Units: An Overview," which identified four types of FIUs based on their structure and role: administrative, law enforcement, judicial or prosecutorial, and hybrid models. The Egmont Group, an international organization of FIUs, was established to facilitate cooperation and information sharing among government FIUs worldwide. It provides a platform for FIUs from 164 countries to collaborate in combating money laundering and terrorist financing. The Egmont Group's efforts align with the IMF's framework for classifying FIUs, contributing to a more cohesive global approach to addressing financial crimes. #aml #compliance

The House Appropriations Committee has just approved the FY25 Financial Services and General Government Appropriations Act, which brings significant changes that government contractors need to be aware of. With nearly $23.6 billion in discretionary funding, this act prioritizes national security, strengthens financial oversight, and cuts back on regulatory overreach. For contractors, this means a focus on combating terrorism financing, enhancing sanctions enforcement, and supporting the integrity of financial markets. However, it also means navigating new restrictions, such as reduced funding for financial regulators and the blocking of certain federal initiatives. Understanding these changes is critical as you plan your contracts and compliance strategies for the upcoming fiscal year. As FY24 winds down, now is the time to align your business with these new priorities to ensure continued success in the federal contracting space. #GovCon #FiscalYear #GovernmentContracting #AppropriationsAct #VisioneerIT

📣 Treasury Reporting Requirements for Russian Sovereign Assets On July 23, 2024, the Treasury's Office of Foreign Assets Control (OFAC) issued reporting instructions under the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act. 🔧 Financial institutions holding Russian sovereign assets must report them to OFAC by August 2, 2024, or within 10 days of detecting such assets. This includes assets held in correspondent or payable-through accounts. 🔒 Reports should include details such as the asset’s location, ownership, description, and value. Institutions may use existing reports from Directive 4 under Executive Order 14024 to meet these requirements. Original source 👉: https://lnkd.in/gkmsjjzx #USsanctions #sanctionsupdate #sanctionscompliance #Sanctions #OFAC #Russiasanctions #FinancialCompliance #EconomicSanctions #REPOforUkrainiansAct

In the past few months, there has been a significant increase in the administration and enforcement of exchange control laws, with our clients receiving compliance requests and enforcement demands issued by the South African Reserve Bank (SARB). Read our article, by Denny Da Silva Chartered Tax Adviser (CTA), Tsanga Mukumba, Gabriel Rybko and Simon Mateus, here: https://lnkd.in/d4zBeFdr.   In the wake of the Financial Action Task Force’s (FATF) greylisting of South Africa, the SARB has intensified its oversight and enforcement of exchange control laws to enhance the effectiveness of anti-money laundering (AML) and counter-terrorist financing (CTF) measures. The SARB has prioritised the safeguarding of the South African balance of payments, fiscus and prevention of unauthorised outflows of funds. Multinational enterprises should therefore ensure their activities and cash flows are in full compliance with South African exchange control regulations to avoid potentially serious consequences of any non-compliance.

Funding FinCEN and Treasury's Office of Terrorism and Financial Intelligence (TFI). On March 21, 2024 Treasury Secretary Janet Yellen appeared before the House Appropriations Committee's Subcommittee on Financial Services and General Government. In her prepared remarks, she noted that "advancing our work abroad requires $231 million for the Office of Terrorism and Financial Intelligence, which provides critical financial intelligence and sanctions-related economic analysis, including to support sanctions related to Hamas, Iran, and Russia. We’ve also requested $216 million for the Financial Crimes Enforcement Network. This will allow us to build on the significant milestone of launching the beneficial ownership reporting system while taking other actions to protect the financial system and combat illicit finance." So ... Treasury is asking for $231 million for TFI, and $216 million for FinCEN. Congress - or at least the Republican-controlled House - isn't buying what the Secretary is selling. Their most recent proposal calls for $227 million for TFI and $190 million for FinCEN. See pages 155 and 159 (of 1,012 pages!) in https://lnkd.in/g59J4iMx