Comprehensively sanctioned geographies
Which control stops dealings touching a comprehensively sanctioned country or region, including logins and addresses, not only names?
A scenario that places here
example"Embargoed country: logins and payments from sanctioned regions"
Channels it applies to
4 of the 20 in the dictionaryWIN ONL REM COR
International wires, online and mobile banking, remittance and money transfer and correspondent accounts: one sector each on the coverage chart, hatched where no scenario reaches it.
Obligations
4 regimes| Regime | Obligation |
|---|---|
| Bank Secrecy Act and its regulations (31 CFR Chapter X) | BSA BSA-AML-14 OFAC Sanctions Screening |
| FATF 40 Recommendations | FATF R.6 Targeted financial sanctions related to terrorism and terrorist financing |
| Anti-Money Laundering and Counter-Terrorism Financing Act (Australia) | AUSTRAC AMLCTF-SANCTIONS Sanctions Screening |
| OFAC framework for sanctions compliance commitments | OFAC OFAC-SCP-3.3 Country and Comprehensive Sanctions Controls |
The obligations, quoted
BSA BSA-AML-14 OFAC Sanctions ScreeningInstitutions shall screen customers, beneficial owners, counterparties and transactions against OFAC and other applicable sanctions lists in real time.
Where programmes usually fall short: List updates lag; No fuzzy matching tuning
Source: Bank Secrecy Act and its regulations (31 CFR Chapter X)
FATF R.6 Targeted financial sanctions related to terrorism and terrorist financingCountries implement targeted financial sanctions regimes giving effect to the UN Security Council resolutions on terrorism and terrorist financing, freezing without delay the funds and other assets of persons and entities designated by or under the authority of the Security Council under Chapter VII (resolution 1267 and successors) or designated by the country under resolution 1373, and ensuring that no funds or assets are made available to or for their benefit; the Interpretive Note sets the designation authorities and procedures, the freezing obligations without delay and without prior notice, the prohibitions, the communication of designations, the reporting duties of institutions, the delisting and unfreezing procedures and access to frozen funds for basic expenses.
Where programmes usually fall short: Freezing dependent on a court order that takes days; No domestic designation mechanism under resolution 1373
Source: FATF 40 Recommendations
AUSTRAC AMLCTF-SANCTIONS Sanctions ScreeningScreen customers and transactions against DFAT consolidated list and UN sanctions to comply with autonomous sanctions.
Where programmes usually fall short: No sanctions screening
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)
OFAC OFAC-SCP-3.3 Country and Comprehensive Sanctions ControlsThe organization must implement geographic controls that prevent prohibited dealings with comprehensively sanctioned jurisdictions including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.
Where programmes usually fall short: Reliance on customer-provided country data without independent verification; Web and mobile channels lacking IP-geolocation controls
Source: OFAC framework for sanctions compliance commitments