ACAMS Germany Chapter

Enforcing #sanction programs is a never ending task, even when all are enjoying the rest of New Year’s Eve #OFAC #amlcompliance #sanctions

I do appreciate people saying the truth, especially when they are subject to a supervisory action. But sometimes the truth is shocking even for seasoned supervisors. The freshly released consent order by FDIC refers that “The President of the Bank told FDIC examiners that Respondent needed to keep its customers’ interests in mind when considering whether to file SARs.” This is compounded by “Respondent’s BSA Officer A admitted to the FDIC that he did not have unilateral authority to file a SAR [and] BSA Officer A told the FDIC that he was as concerned with losing a customer as he was with identifying and reporting suspicious activity.” #amlbsa #amlcft #compliance #banking

Quality of data is key for an effective #AML program Poor data equates to defective #antifinancial crime https://lnkd.in/e2FWevbE

On 17-18 December, the Financial Action Task Force (FATF) hosted the second Virtual Assets Contact Group Symposium to help strengthen global efforts to assess and mitigate the risks of Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs).    More than 650 participants from over 100 jurisdictions from across the FATF Global Network gathered online to discuss best practices in developing VASP risks assessments and implementing mitigating measures. As the sector undergoes fast changes, it is crucial that all countries take responsibility in assessing and mitigating risks associated with virtual asset financial activities and providers.    📅 The FATF continues to monitor implementation of FATF Standards in relation to VAs/VASPs, and will be publishing a targeted update on progress in 2025.    Read the fifth update on jurisdictions' compliance with applying anti-money laundering and counter-terrorist financing measures to virtual assets, which found that global implementation is still lagging: https://lnkd.in/df2wEb6J    #FATF #AML #FollowTheMoney

Der Bundestag hat endlich eine Initiative der Bundesregierung zur Regulierung des digitalen Finanzmarkts angenommen https://lnkd.in/dVZd3H_K

Playing as front person to help a designated party to escape the consequences of OFAC sanction program comes with a price. https://lnkd.in/e_C5SeYk #ofac #sanction #sdn

One of the most striking findings of Europol report is that “86% of the most threatening criminal networks make use of legal business structures”. This can only happen because of lapses at gatekeepers side and not yet adequate practices for UBO identification and public disclosure. #ubo #organisedcrime #amlcft #europol https://lnkd.in/eivEnRqG

Another interesting report from EBA on the functioning of EU AML arrangements. This time is about the college of AML supervisors for which the EBA found improvements in comparison to 2023 review, but identified two key areas in which the progress made by competent authorities was seen as insufficient, namely: 1) Implementing the risk-based approach to the organisation of colleges, which led to an allocation of resources not appropriate; 2) Ensuring that discussions on the need for a common approach are meaningful and systematic. The EBA found that few colleges had meaningful discussions on these aspects. As a result, competent authorities were rarely able to identify whether there were risks and/or issues that should be addressed in a coordinated manner. #aml #amlcft #amlcolleges #eba #singlerulebook https://lnkd.in/ektsN-aG

𝐄𝐔 𝐚𝐝𝐨𝐩𝐭𝐬 𝟏𝟓𝐭𝐡 𝐩𝐚𝐜𝐤𝐚𝐠𝐞 𝐨𝐟 𝐫𝐞𝐬𝐭𝐫𝐢𝐜𝐭𝐢𝐯𝐞 𝐦𝐞𝐚𝐬𝐮𝐫𝐞𝐬 𝐚𝐠𝐚𝐢𝐧𝐬𝐭 #𝐑𝐮𝐬𝐬𝐢𝐚 1️⃣ 84 new individual listings, including senior managers in leading companies in the energy sector, individuals responsible for children deportation, propaganda and #circumvention, as well as Russian defence companies and shipping companies responsible for the transportation of crude oil and oil products by the sea. The EU also targeted various Chinese actors supplying drone components and microelectronic components to Russia. 2️⃣ 52 #vessels originating from third countries added to the list of vessels subject to a port access ban and ban on provision of a broad range of services related to maritime transport. 3️⃣ 32 new entities added to the list of companies directly supporting Russia’s military and industrial complex, which will be subject to tighter export restrictions concerning dual use goods and technologies. Some of these entities are located in China, India, Iran, Serbia and the UAE and have been involved in the circumvention of trade restrictions. 4️⃣ The Council decided to prohibit the recognition or enforcement in the EU of certain rulings issued by Russian courts, in order to better protect EU companies from litigations with Russian counterparts. Also, the Council introduced a derogation allowing the release of cash balances held by EU central securities depositories (CSDs), prior NCA authorization. https://lnkd.in/dMTANS3n.