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Home » Publications » Sanctions, AML, Anti-Corruption Publications
Sanctions, AML, Anti-Corruption Insights
Global Magnitsky Sanctions, Sanctions, United States China Law and Policy
United States Imposes Global Magnitsky Sanctions on Cambodian Officials
The imposition of Global Magnitsky anti-corruption sanctions on two Cambodian related to the Ream Naval Base is strategically significant in the context of U.S. concerns about China's activities and influence in Cambodia.
Sanctions: OFAC Authorizes Humanitarian Aid to Afghanistan
Sanctions Update ▪ October 4, 2021 ▪ PDF OFAC Authorizes Afghanistan Humanitarian Aid and Activities Otherwise Prohibited by Counter-Terrorism Sanctions, Publishes FAQs On September 24, 2021, the Department of…
Academic Espionage, Business Ethics & Conduct, CFIUS, Doing Business in the United States, Foreign Investment in the United States, Global Magnitsky Sanctions, Iran Sanctions, Russia Sanctions, Sanctions, Tech War, Technology Export Control, United States China Law and Policy
Post-2020 Election Outlook: 5 Issues to Keep Watching
After the 2016 Presidential election, MassPoint PLLC published five issues to watch in 2017 (and beyond). We revisit our predictions on the five issues, which we expect to remain watch-worthy under the Biden Administration.
Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions, United States China Law and Policy
Corruption, Human Rights, and Geostrategy: U.S. Sanctions Belt & Road Project Company
The United States has targted a Belt& Road project with Global Magnitsky Sanctions. The move is significant, and might signal a ratcheting up of U.S. opposition to the BRI, which has largely comprised rhetoric, diplomatic lobbying, and relatively tepid competition, such as by the establishment of the U.S. International Development Finance Corporation (DFC).
U.S. Targets Chinese Belt & Road Project With Global Magnitsky Sanctions
The Treasury Department's announcement of the sanctions speaks to the foreign policy and geostrategic significance of the UDG sanctions action. The release speaks of China's "malign" investment in Cambodia, its use of the UDG projects in Cambodia to "advance ambitions to project power globally," "disproportionality benefit" itself through BRI projects, and concerns that the Dara Kakor project "could be converted to "host military assets." The Treasury Department's language echoes U.S. concerns about the BRI and other Chinese international project financing activities, including that China engages in "debt trap" financing.
Anti-Corruption, Anti-money laundering, Doing Business in the United States, MassPoint News
Regulatory landscape for legal firms in the U.S.: Hdeel Abdelhady RegTech Podcast
In a two part RegTech podcast, MassPoint's Hdeel Abdelhady talked with Accuity about issues of financial crime, due diligence, and related issues around lawyers as gatekeepers of the financial system.
Anti-Corruption, Anti-money laundering, Iran Sanctions, MassPoint News, Sanctions
COVID, Supply Chains, Sanctions & Financial Crime: Hdeel Abdelhady-Accuity Q&A
In the second part of her Q&A with Accuity, Hdeel Abdelhady shared her thoughts on the current and potential impacts of the COVID-19 pandemic on global supply chains, sanctions, and financial crime
Iran Sanctions, Sanctions
Iran Sanctions: OFAC Exempts Medicine, PPE Manufacturers (EO 13902)
In guidance issued on June 5, 2020, OFAC explained that manufacturers in Iran of medicine, PPE, childcare items, and other essential supplies will be exempt from sanctions targeting Iran's manufacturing sector pursuant to EO 13902.
Doing Business in Emerging Markets, MassPoint News, Sanctions
Hdeel Abdelhady-Accuity Q&A: Sanctions Trends, Lawyers as Gatekeepers
Hdeel Abdelhady shared her insights with Accuity on the sanctions landscape and the role of lawyers in fighting financial crime
Global Magnitsky Sanctions, Sanctions
Global Magnitsky Human Rights and Corruption Sanctions Overview
With the adoption of the Global Magnitsky Sanctions, the United States added a powerful weapon to its already formidable legal arsenal. This publication provides an overview of the Global Magnitsky Sanctions.
Doing Business in the United States, Global Magnitsky Sanctions, Iran Sanctions, MassPoint News, Sanctions, Tech War
Sanctions Compliance in a State of Flux: Trends and Guidance Amid Global Upheaval
MassPoint Legal and Strategy Advisory PLLC's Hdeel Abdelhady discussed sanctions trends and guidance, as well as issues related to the COVID-19 pandemic, in a live event presented by the Association of Certified Financial Crime Specialists (ACFCS) and Accuity.
National Security Law, Sanctions
OFAC Sanctions Jurisdiction Over US-Origin Technology: SITA Enforcement
OFAC's sanctions enforcement against SITA, the Switzerland-based provider of global air transport technology and services, premised U.S. sanctions jurisdiction on the provision of U.S.-origin technology and the involvement in transactions of networking hardware and servers located in the United States.
Russia Sanctions, Sanctions
U.S. Sanctions on Nord Stream 2 and TurkStream Pipeline Projects (PEESA)
On December 20, 2019, the President signed into law the National Defense Authorization Act for Fiscal Year 2020 (NDAA), which authorizes the President to impose sanctions on foreign persons that knowingly sell, lease, or provide vessels for the construction of the Nord Stream 2 or TurkStream pipeline projects. The policies advanced by the NDAA are consistent with prior U.S. policy and legislation, particularly the Countering America's Adversaries Through Sanctions Act. This MassPoint publication discusses PEESA's policies, sanctions mechanics, the relationship between PEESA and CAATSA, and key takeaways.
Doing Business in Emerging Markets, Iran Sanctions, National Security Law, Sanctions, United States China Law and Policy
OFAC Cosco Shipping Tanker (Dalian) Co., Ltd. General License K: Analysis
General License K authorizes, until 12:01 eastern time on December 20, 2019 (essentially, through the end of December 19 eastern time), the above-listed prohibited transactions where they directly or indirectly involve Cosco or entities owned 50% by Cosco and are "ordinarily incident and necessary to the maintenance or wind down of transactions."
U.S. Sanctions Chinese Shipping Companies: Legal and Practical Points
The imposition of sanctions on the Chinese companies and executives—particularly on units of the high-profile, state-owned COSCO at a critical juncture in the U.S.-China trade war and shortly after both countries took conciliatory steps—reinforces the Trump Administration's stated posture of aggressively enforcing Iran secondary sanctions in furtherance of its policy objectives.
OFAC's Reporting Rules: Big Lessons From "Small" Cases
Two "small" cases enforcing OFAC's reporting rules indicate OFAC's RPPR compliance expectations and enforcement posture. These and a recent sectoral sanctions enforcement show again that cases involving small (or no) monetary penalties can yield big compliance lessons.
Anti-Corruption, Critical Minerals, Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC, MassPoint News
CFTC's Corruption Crackdown Consistent With Trump Admin Strategy, Says Hdeel Abdelhady
Ms. Abdelhady addressed how the CFTC's current investigation of Glencore and its broader anti-corruption plans might fit with the Trump Administration's wider anti-corruption strategy targeting the extractives industry globally, as well as the how the CFTC, which lacks direct FCPA enforcement authority, might take a page from the NYDFS' playbook and indirectly enforce an anti-corruption agenda under the Commodities Exchange Act.
Anti-money laundering, Banking Law & Regulation, Doing Business in the United States, MassPoint News, Sanctions
Global Payments: Hdeel Abdelhady on a Russia-led Non-Dollar Payments System
Hdeel Abdelhady shared her insights with PaymentsSource on a Russia-led effort to build a non-U.S. dollar payments system, to insulate against U.S. sanctions and U.S. control more broadly. Ms. Abdelhady has for years worked on the U.S.-dollar and financial system links to U.S. sanctions enforcement jurisdiction. Her work on the topic of U.S. dollar and financial system tied legal jurisdiction has been quoted, leveraged, and consulted frequently in the United States and abroad.
Anti-money laundering, Banking Law & Regulation, Doing Business in the United States, Iran Sanctions, National Security Law, Sanctions
OFAC Expands Reporting Requirements
On June 21, the Office of Foreign Assets Control (OFAC) issued an interim final rule (IFR) substantially revising sanctions reporting regulations. The most significant amendment was to OFAC's rejected transactions reporting rule, which now, for the first time, applies not just to U.S. financial institutions, but also to U.S. businesses, nonprofits, and individuals. The rule also appears to apply to foreign entities owned or controlled by U.S. persons. Public comments on the IFR are due by July 22, 2019.
Banking Law & Regulation, Doing Business in Emerging Markets, Sanctions
In International Business, Sweat the "Small" Stuff
Business transactions necessarily become more complex when they involve two or more countries. Among other tasks, it is necessary to understand the content and applicability of foreign laws, retain local counsel, address conflict of law issues, and make (hopefully strategically, rather than as an afterthought) governing law and dispute resolution selections.The focus on more substance aspects of international transactions should not be exclusive.
Anti-money laundering, Banking Law & Regulation, MassPoint Legal and Strategy Advisory PLLC, MassPoint News
Hdeel Abdelhady Appointed to ABA Task Force on Gatekeeper Regulation and the Profession
MassPoint's Hdeel Abdelhady has been appointed to the American Bar Association's Task Force on Gatekeeper Regulation and the Profession.
Iran Sanctions, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, Sanctions
Hdeel Abdelhady on NPR: United States Ratchets Up Iran and North Korea Sanctions
MassPoint's Hdeel Abdelhady spoke with NPR about the ratcheting up of U.S. sanctions, secondary sanctions, and the potential consequences of sanctions overuse. To learn more about the mechanics of U.S. sanctions, and particularly about the role of the American dollar, financial system, and economy in extending the global reach of U.S. sanctions, read Hdeel Abdelhady's Reuters insight piece, Reimposed U.S. anti-Iran sanctions leverage American economic power.
Anti-money laundering, Banking Law & Regulation, Doing Business in the United States
Bank Shareholders as Anti-Money Laundering Enforcers: Corporate Governance-AML Nexus
Two proxy advisors are urging Deutsche Bank's shareholders to vote against directors and senior managers for AML compliance lapses. The advice is significant as it clearly connects anti-financial crime compliance to corporate governance by activating bank shareholders as powerful enforcers anti-money laundering expectations. If Deutsche's shareholders heed the calls of proxy advisors and unseat members of the bank's management for AML lapses, they will set a cautionary precedent for other publicly-owned banks. But even if Deutsche's shareholders do not so vote, the proxy advice given by ISS and ECGS has communicated a clear message that bank anti-money laundering compliance is part and parcel of corporate governance and a measure of directors' and senior officers' overall performance.
Banking Law & Regulation, Doing Business in Emerging Markets, Doing Business in the United States, Sanctions
OFAC's Russia Sectoral Sanctions Directives Apply to Trade-Based Debt: Analysis
The Haverly case is instructive as it clarifies OFAC's position, with respect to Haverly and likely more broadly, as to the meaning of "debt" under Directive 2, which prohibits, by U.S. persons and within the United States, dealings in "new debt" issued by parties that are listed on the OFAC-maintained Sectoral Sanctions Identifications List (SSIL) or not so listed but are owned 50% or more by one or more sanctioned parties.
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, Doing Business in Emerging Markets, Doing Business in the United States, Sovereign Immunity
Anti-Corruption Enforcement is Globalized
As anti-corruption standards and enforcement practices become more uniform, cooperation among enforcement authorities will increase in frequency and effectiveness. In the FCPA enforcement context and in others, authorities have imposed record-setting fines, and likely will continue to do so with greater frequency, particularly where violations are egregious, widespread, or have broad impact. In such an environment, monetary penalties for avoidable violations may no longer be absorbable as the cost of doing business. As a matter of good business practice, companies of all sizes should take steps to strengthen compliance programs appropriately for their industries, organizational structures, home obligations, and the jurisdictions in which they do business.
Banking Law & Regulation, Doing Business in the United States, Iran Sanctions, Sanctions
OFAC Expanded General License for U.S. Persons to Transact in Certain Inherited and Other Property in Iran
Under amended Section 560.543 of the ISTR, individuals who are U.S. citizens and permanent residents[2] "are authorized to engage in transactions necessary and ordinarily incident to the sale of real and personal property in Iran and to transfer the proceeds to the United States," but only if the real and personal property was (1) "acquired before the individual became a U.S. person" or (2) was "inherited from persons in Iran.
Academic Espionage, Academic Research, China Initiative, Doing Business in the United States, Foreign Agents Registration Act, Foreign Influence in Academia, National Security Law, Sanctions, Tech War, Technology Export Control, Technology Transfer, United States China Law and Policy, University Export Controls
U.S.-China Trade, Technology and American Academia: The DOJ China Initiative
On national security grounds, the United States is developing and implementing a whole-of-government approach to maintain the country's technological edge through legal and policy measures to restrict Chinese access to U.S. technology and intellectual property, including by: (1) limiting or prohibiting certain foreign investment and commercial transactions; (2) adopting export controls on emerging technologies; (3) instituting supply chain exclusions; (4) curbing participation in academic and other research; and (5) combating cyber intrusions and industrial and academic espionage.[2] Additionally, concerns about Chinese government influence have spurred proposals to regulate the activities of entities viewed as Chinese government influence operators.
Academic Espionage, Academic Research, China Initiative, Doing Business in Emerging Markets, Doing Business in the United States, Foreign Influence in Academia, Foreign Investment in the United States, National Security Law, Sanctions, Tech War, Technology and Human Rights, Technology Export Control, Technology Transfer, United States China Law and Policy
U.S.-China Trade, Technology & Global Policy Issues: INFOGRAPHIC
This graphic depicts key issues between the United States and China, as identified by the United States as of January 26, 2019. This is not an exhaustive depiction, but captures key categories and sub-categories of Chinese state and private practices, state policies, and state structural characteristics that are the subject of U.S. government complaints (as raised from within and outside of the Trump Administration).
Critical Minerals, Doing Business in Emerging Markets, Doing Business in the United States, Environmental Social Governance (ESG), Foreign Investment in the United States, Global Magnitsky Sanctions, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, National Security Law, Sanctions, United States China Law and Policy
Event: Critical Minerals, National Security, and Supply Chains
Now that the Trump Administration has declared a policy to reduce dependency on foreign sources for critical minerals, how will the Administration go about achieving its stated objective? What legal consequences—including in the areas of national security, trade, anti-corruption, and environmental law—might flow? Our multi-disciplinary panel will discuss the science and practical importance of "critical minerals," recent and potential U.S. legal and policy developments, and the potential impacts of U.S. actions on minerals on manufacturing, supply chains, and the markets.
Anti-Corruption, Business Ethics & Conduct, Doing Business in Emerging Markets, Doing Business in the United States, National Security Law, United States China Law and Policy
Trump's Africa Strategy Targets Corruption. Extractives, and Chinese Presence
The Trump Administration's newly released Africa Strategy is likely to bring greater anti-corruption enforcement, particularly against Chinese state-owned and private firms, as well as against African officials, and African and third country private parties. Extractives industries, particularly involving nonfuel minerals like cobalt, are likely to be of particular interest.
Senate Bill Seeks Sanctions in Khashoggi Case, End to Yemen War
The Saudi Arabia Accountability and Yemen Act of 2018 seeks further sanctions for those responsible for the death of Jamal Khashoggi, including at the highest levels of the Saudi establishment, and an end to the war in Yemen. The Act adds a chapter to the unfolding story of Congress' increasing sanctions activism, stemming from a lack of faith that the Trump Administration will enforce sanctions with fidelity to law and national policy.
Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, Sanctions
American Economic Power Fuels Sanctions
America's economic and financial heft facilitates the extraterritorial reach of U.S. sanctions and other law. For example, global transactions denominated in U.S. dollars and processed through the U.S. financial system create a jurisdictional nexus between the United States and foreign parties, property, and events.
Doing Business in Emerging Markets, Doing Business in the United States, Global Magnitsky Sanctions, Sanctions
Global Magnitsky Sanctions FAQs
The Global Magnitsky Act and Global Magnitsky Sanctions (GMS) are in the public discourse as a result of recent events, such as the case of U.S.-based journalist Jamal Khashoggi and the imposition of Global Magnitsky Sanctions on two Turkish officials in August. To help the public understand the Global Magnitsky framework, MassPoint Legal and Strategy Advisory has published the Global Magnitsky Sanctions FAQs
Doing Business in the United States, MassPoint News, National Security Law, Sanctions, Tech War, United States China Law and Policy
U.S. Law as Trade War Weapon
The ZTE case puts into focus the Trump Administration's apparent strategy to use U.S. sanctions, along with anti-corruption and anti-money laundering laws, as trade war weapons, specifically as "economic tools" and "tools of economic diplomacy" that "can be important parts of broader strategies to deter, coerce, and constrain adversaries."
USMCA Borrows From Secondary Sanctions Playbook to Freeze Out "Non-Market" Nations
The recently published text of the United States-Mexico-Canada trade agreement (USMCA) includes a peculiar provision that confers on each of the parties the right to terminate the USMCA if any of the other parties enters into a "free trade agreement" (FTA) with a country determined by any of the USMCA countries to be a "non-market" economy. Insofar as the USMCA requires the parties to choose between maintaining the trilateral trade agreement or entering into an FTA with a non-market economy country, the USMCA imports the premise that underlies U.S. secondary sanctions.
Anti-money laundering, Banking Law & Regulation
Banking Transparency for Sanctioned Persons
On September 7, 2018, Congresswoman Mia Love (R-UT) introduced in the House of Representatives H.R. 6751, the Banking Transparency for Sanctioned Persons Act of 2018 to "increase transparency with respect to financial services benefitting state sponsors of terrorism, human rights abusers, and corrupt officials." This update discusses the Banking Transparency Act's provisions and what it conveys about the current U.S. legal climate around corruption and human rights sanctions, Congress' increasingly activist sanctions posture, and the risk management and compliance inferences that U.S. and foreign financial institutions should draw from the Banking Transparency Bill when viewed in context.
Business Ethics & Conduct, Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions, Tech War, Technology and Human Rights, United States China Law and Policy
Human Rights, Law & Technology Supply Chains
Some Congress members are lobbying the Administration to impose human rights sanctions on Chinese officials and companies responsible for or complicit in abuses against China's Uighur Muslim minority and other minorities. Two companies named, Dahua Technology and Hikvision, are very large, China-based global firms that produce surveillance products and systems. The bottom line is that the tech industry should take note of the development (even if no sanctions are imposed), as it foreshadows the legal and reputation risk issues they will, without doubt, face in connection with tech-enabled abuses, privacy encroachments, and other conduct by consumers of tech products and services.
Anti-Corruption, Business Ethics & Conduct, Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions
Global Magnitsky: The Swiss Army Knife of Sanctions
The Global Magnitsky Sanctions apply worldwide, without any requirement of a jurisdictional nexus with the United States. They define corruption broadly enough to capture a wide range of conduct and persons. The sanctions target "serious human rights abuse," but do not define the term. Moreover, the sanctions are readily deployable. No tailored legislation, executive order, or other administrative process—other than a sanctions determination by the Secretary of Treasury in consultation with the Secretary of State—is required to impose sanctions anywhere, anytime. Given their global reach, substantive breadth, and wide applicability, the Global Magnitsky Sanctions have distinct utility value as they can be readily employed for multiple legal, policy and strategic objectives. They are the Swiss Army Knife of sanctions. To date, 78 individuals and entities have been sanctioned for corruption and human rights abuses. The most recent of these sanctions actions, against Turkey, has triggered speculation as to its motives and objectives. This is discussed below, as are some of the provisions that suggest the Global Magnitsky Sanctions were formulated for sweeping applicability and enforcement latitude.
Anti-Corruption, Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions
United States Sanctions High-Ranking Turkish Officials Under Global Magnitsky
Today the United States took the extraordinary step of imposing sanctions on Turkey's Minister of Justice Abdulhamit Gul and Minister of Interior Suleyman Soylu. The sanctions were imposed under the Global Magnitsky Sanctions program, promulgated by Executive Order 13818 pursuant to the Global Magnitsky Act of 2016 and the International Emergency Economic Powers Act, among other legal authorities.
Senate Bill Seeks to Protect Magnitsky Law from Trump-Putin Deal
The introduction of legislation after the Helsinki summit to constrain the President's sanctions authority vis-a-vis Russia is not surprising. As anticipated in this MassPoint post of July 18, "the Helsinki meeting could have legal consequences, should Congress move to insert itself, beyond its standard law-making and oversight role, in sanctions and trade matters," including in the mold of CAATSA.
Anti-Corruption, Sanctions
Russia Summit Could Spur Congressional Activism on Sanctions, Trade
The meeting in Helsinki between the U.S. and Russian presidents has (as presumably everyone knows) sparked strong reactions in the United States, particularly in response to the U.S. President's performance. Beyond the politics of the moment and its aftermath, the Helsinki meeting could have legal consequences, should Congress move to insert itself, beyond its standard law-making and oversight role, in sanctions and trade matters. And not just with respect to Russia. There are a number of ways that Congress can play a greater role in sanctions and trade. Such Congressional involvement, if it materializes, would likely be designed to constrain the President, such as by restricting his ability to lift, not impose or modify sanctions through Executive action.
Banking Law & Regulation, Iran Sanctions, Sanctions
Personal Remittances and Proceeds of Inheritances from Iran After U.S. Withdrawal from Iran Deal
For U.S. persons seeking to engage in permitted noncommercial, personal remittance or inheritance-related transactions, the higher risk sensitivity of some third country (and U.S.-based) financial institutions may complicate (or thwart in some cases), legal transactions. In light of this, persons seeking to engage in such legal transactions in the post-U.S. JCPOA withdrawal environment should exercise extra care in initiating and executing legal transfers with third country financial institutions.
United States Sanctions Malaysia Agent of Iranian Airline
The Treasury Department's Office of Foreign Assets Control (OFAC) today sanctioned Malaysia-based Mahan Travel and Tourism Sdn Bhd ("Mahan Travel") pursuant to Executive Order 13,224. Rather then information should be taken as a prompt to other travel agencies or vendors that directly or indirectly "act for or on behalf of Mahan Air" to disassociate from the airline. Such other travel agencies or vendors should, at minimum, review and understand today's Mahan Travel action, assess their sanctions and related risk (legal, commercial, etc.) and take defensive compliance steps that are appropriate to their sanctions/legal exposure and commercial position. The broader takeaway from today's OFAC action against Mahan Travel is that it reinforces the fact that U.S. sanctions and other laws are global in reach. Non-U.S. parties should take note of their potential exposure to U.S. sanctions or other legal enforcement actions.
Anti-Corruption, Anti-money laundering, Business Ethics & Conduct, Critical Minerals, Doing Business in Emerging Markets, Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC
Canary in the Cobalt Mine: Glencore Corruption Probe May Not Be a One Off
The U.S. arm of Glencore, the global commodities trading and mining giant, has been served a subpoena by the U.S. Department of Justice, according to news accounts. The DOJ's subpoena reportedly seeks documents and information pertaining Glencore's business in the Democratic Republic of Congo (DRC), Nigeria and Venezuela to assess potential violations of U.S. anti-money laundering laws and the Foreign Corrupt Practices Act (FCPA), the principal U.S. law essentially prohibiting the bribery of foreign officials for business gain by U.S. companies and others subject to United States' jurisdiction (broadly construed and applied).The Glencore subpoena may not be a one-off and it should be viewed-- at least for risk assessment and compliance improvement purposes-- as potentially part of a larger U.S. strategy to proactively target corruption and, by extension, money laundering, in Africa and Africa's extractives industries. (The wider context is that the Trump Administration views U.S. anti-corruption, anti-money laundering and sanctions laws and their enforcement as "tools of economic diplomacy", including to advance trade and other policy objectives).
Anti-Corruption, Business Ethics & Conduct, Global Magnitsky Sanctions, Sanctions
Global Magnitsky Regulations: U.S. Multinationals and Dual Citizens Have Heightened Sanctions Exposure
U.S. multinational companies/entities as well as dual citizens/nationals should understand their heightened sanctions exposure under the Global Magnitsky Act, EO 13,818 and the GloMag Regulations. Multinational companies/entities would be well-advised to update their risk-based compliance programs and educate their relevant personnel to make compliance more likely, including by avoiding inadvertent violations of the Global Magnitsky Act, EO 13,818 and the GloMag Regs.
MassPoint Legal and Strategy Advisory PLLC, Sanctions, Tech War, Technology Export Control, Technology Transfer, United States China Law and Policy
ZTE: Was the Export Ban the Right Penalty?
The sentiments expressed by Senator Rubio and others reflect commercial, competition, policy, and strategic concerns held by business, policy makers, defense and national security officials, and others about China and Chinese firms like ZTE and Huawei. But when raised in the context of and as a justification for a specific legal enforcement action, the sentiments blur the lines between what should primarily be an enforcement based on facts and applicable laws, rather than an instrument for advancing wider policy objectives that are not specifically advanced by the laws applicable to the conduct for which ZTE was penalized. And, while Secretary Ross' stated rationale to impose the harsher penalty to change ZTE's behavior may have been sound, the recommendation of the career professionals with expertise in sanctions and export controls enforcement should, perhaps, have carried the day. Secretary Ross' description of the process leading to the export ban and the mess that has followed it give more reason to ask whether, in the first place, the export ban was the appropriate remedy as a matter of applicable laws and the objectives served by them.
Anti-Corruption, Business Ethics & Conduct, Doing Business in the United States, Global Magnitsky Sanctions, Sanctions
Global Magnitsky Sanctions "a Central Tool of U.S. Foreign Policy"
United States Lobbies G-7 Nations to Adopt Global Magnitsky Sanctions, Now a "Central Tool of U.S. Foreign Policy" As discussed extensively on this website and at MassPoint PLLC, the…
Anti-Corruption, Banking Law & Regulation, Doing Business in the United States
U.S. and International Business & Banking
Bank and Money Services Business Licensing and Compliance MassPoint works with U.S. and foreign clients wishing to establish banks and money services businesses (MSBs)/money transmitters from assessment of prospects…
Anti-Corruption, Business Ethics & Conduct
The Value of Integrating News Awareness into Corporate Compliance and Risk Management
The case of Michael Cohen, "personal lawyer" to the U.S. President, continues to yield rich legal, compliance and risk management lessons for a growing group that includes U.S. and foreign companies, banks, lobbyists, government officials, and lawyers. Recent developments in the Cohen matter highlight how news awareness can enhance compliance and risk management for companies and others. Unlike AT&T and Novartis, most companies will not find themselves entangled in headline news of national importance, but enough of them are likely to get caught flat-footed by news about them or their business partners and peers (such as in the same industry, where news of one company's bad behavior can lead law enforcement authorities to scrutinize peer companies in industry sweeps).
Academic Espionage, Doing Business in the United States, Foreign Investment in the United States, Sanctions, Technology Export Control, Technology Transfer, United States China Law and Policy
U.S.-China Trade and Tech War on Three Fronts
Much of the talk of trade war between the United States and China, and perhaps other countries, has focused on traditional trade measures and counter-measures like tariffs that strike at the core of international trade: most basically, the movement of goods and services across international borders. But there are two additional fronts of a U.S.-China trade war (thus far): intellectual property and the use of U.S. sanctions and other laws to "coerce and deter" economic rivals like China.
Doing Business in the United States, Foreign Investment in the United States, MassPoint Legal and Strategy Advisory PLLC, National Security Law, Sanctions, Tech War, Technology Export Control, Technology Transfer, United States China Law and Policy
House Bill "Blocks Bailout" of ZTE After Export Ban
On May 17, the House Appropriations Committee unanimously approved a measure to block the Commerce Department from using appropriated funds to alter the export ban (i.e., the "denial order") that the agency activated against ZTE on April 15, 2018. The ZTE measure was approved as an amendment to the fiscal year 2019 bill funding the Departments of Commerce and Justice, Science, and Related Agencies ("Commerce Appropriations Bill"), which was approved by the Appropriations Committee on May 17.
Hdeel Abdelhady Discussed the Michael Cohen Matter on MSNBC
Hdeel Abdelhady joined MSNBC's Ari Melber on May 9 to discuss developments in the Michael Cohen case, including Michael Avenatti's report purporting to contain details of Cohen's transactions with Novartis, AT&T, Viktor Vekselberg and others. Watch the segment here: MassPoint's Hdeel Abdelhady on The Beat With Ari Melber
Anti-Corruption, Business Ethics & Conduct, Doing Business in Emerging Markets, Doing Business in the United States, Global Magnitsky Sanctions, Sanctions
Trump Administration Supercharged Global Magnitsky Corruption and Human Rights Sanctions
Beyond the parameters of the Global Magnitsky Act, EO 13818 markedly enlarges the range of sanctionable conduct and persons. The differences between the language of EO 13818 and the Global Magnitsky Act are substantive and significant. In several instances, EO 13818 expands sanctions by omitting the Act's qualifying language, adding new bases for sanctions, and/or leaving key terms undefined. Key instances of EO 13818's broad and/or uncertain language are discussed below.
Banking Law & Regulation, Doing Business in Emerging Markets, Doing Business in the United States, Iran Sanctions, Sanctions
Iran Sanctions Update: U.S. Withdrawal From JCPOA
The United States today unilaterally withdrew from the Iran Nuclear Deal (the Joint Comprehensive Plan of Action (JCPOA)). The U.S. Treasury Department and the White House have announced that those sanctions that were lifted as part of the JCPOA framework will, as expected, be re-imposed. The Office of Foreign Assets Control at Treasury (OFAC) announced today that it will institute 90-day and 180-day "wind down" periods, after which previously lifted U.S. sanctions will again take effect. For example: Starting August 7, 2018, the import to the United States of Iranian carpets and certain foodstuffs will be prohibited, as will the export and re-export to Iran of commercial passenger aircraft and related parts and services. Starting on November 5, 2018, foreign financial institutions will be subject to U.S. sanctions for transactions with the Iran Central Bank and designated Iranian financial institutions.
Anti-Corruption, Anti-money laundering, Business Ethics & Conduct, China Initiative, Critical Minerals, Critical Resources, Doing Business in Emerging Markets, Doing Business in the United States, Global Magnitsky Sanctions, National Security Law, Sanctions, United States China Law and Policy
Trump Administration Targets Chinese Dominance, Corruption in Africa
Notably, in the two pages of the NSS that are devoted to the National Security Strategy in the Africa context, none of Africa's 54 nations are mentioned, but China is named twice. The NSS notes with concern China's "expanding . . . economic military presence in Africa, growing from a small investor in the continent two decades ago into Africa's largest trading partner today." China's methods and influence in Africa are described unflatteringly. "Some Chinese practices," the NSS states bluntly, "undermine Africa's long-term development by corrupting elites, dominating extractive industries, and locking countries into unsustainable and opaque debts and commitments."
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions
President Trump Promulgates Global Magnitsky Sanctions: EO 13818 Analysis
The Global Magnitsky Sanctions are extraordinary for a number of reasons. First, they are global in reach and require not jurisdictional nexus between the United States and the corrupt acts and human rights abuses they target. As to corruption, both the Global Magnitsky Act and EO 13818 define it broadly, well beyond U.S. and international frameworks that are concerned primarily or exclusively with bribery. The Global Magnitsky Sanctions also depart from U.S. and international anti-corruption frameworks by directly penalizing foreign government officials for corrupt acts. As discussed above, EO 13818 significantly expands the scope and reach of the Global Magnitsky Act and, in doing so, employs extraordinary theories of liability, such as strict and vicarious liability on the leaders or officials of any foreign entity that engaged in covered corrupt acts. Independently and together, the provisions of EO 13818 empower the United States, and particularly the Executive Branch, to sanction a wide range of persons and conduct without meeting the due process, evidentiary, or other requirements that would apply in U.S. courts. As indicated in a prior installment of this MassPoint series, 52 individuals and entities have so far been sanctioned under EO 13818. It remains to be seen how the Trump Administration (or subsequent administrations) will implement the Global Magnitsky Sanctions. For now, foreign persons in particular—both government and private—should familiarize themselves with the Global Magnitsky Sanctions and assess their risk for liability, particularly for facilitating corrupt acts such as by transferring the proceeds of corruption.
Anti-money laundering, Banking Law & Regulation, National Security Law
Trump Attorney's Curiously Public Suspicious Activity Report
Federal law prohibits the disclosure of the existence of Suspicious Activity Reports. So how did the existence of a Suspicious Activity Report linked to the President's lawyer become public?
Business Ethics & Conduct, Global Magnitsky Sanctions, Sanctions, United States China Law and Policy
U.S. Lawmakers Raise Possibility of Magnitsky Sanctions on Chinese Officials
According to reports, members of Congress and other U.S. officials have raised the possibility of imposing U.S. financial and/or immigration sanctions on Chinese officials for human rights abuses in…
Congress Members Urge Trump Administration to Apply Global Magnitsky Sanctions to Sudan
In a March 28, 2018 letter to the Deputy Secretary of State, a bipartisan group of 57 members of Congress expressed "grave concern," following the partial lifting in late…
Anti-Corruption, Global Magnitsky Sanctions, Sanctions
Pompeo Pledges to Use Magnitsky Laws to "Full Capacity"
On April 12, 2018, current CIA Director and Secretary of State Nominee, Mike Pompeo, testified before the Senate as part of the confirmation process. In response to a question…
Anti-Corruption, Anti-money laundering, Business Ethics & Conduct, Global Magnitsky Sanctions, Sanctions
United States Directly Sanctions Foreign Government Officials for Corruption
Magnitsky Laws and Sanctions Series, No. 4 | April 6, 2018 | By Hdeel Abdelhady Departing from Prevailing Legal Standards, United States Directly Sanctions Foreign Government Officials for Corruption On…
House Resolution Calls on U.S. Government to Apply Sanctions for Human Rights Abuses in Ethiopia
House of Representatives Calls on Executive Branch to Apply Global Magnitsky Sanctions to Human Rights Abuses in Ethiopia On April 10, 2018, the U.S. House of Representatives agreed to…
Anti-Corruption, Anti-money laundering, Banking Law & Regulation
FinCEN Guidance on Customer Due Diligence (CDD) Rule 2018
The Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 published guidance on the Customer Due Diligence Requirements for Financial Institutions rule (the "CDD Rule) that will come into effect on May 11, 2018. FinCEN's CDD Guidance, in the form of frequently asked questions, is comprised of 36 questions and answers covering a range of issues, from the scope of due diligence up the ownership chain of legal entities to due diligence requirements applicable (or not) to foreign banks.
Anti-Corruption, Doing Business in the United States, Global Magnitsky Sanctions, Sanctions
U.S. Multinationals, Dual Citizens May Have Greater Magnitsky Sanctions Exposure
The Global Magnitsky Act defines a "foreign person" as "any citizen or national of a foreign state (including any such individual who is also a citizen or national of the United States), or any entity not organized solely under the laws of the United States or existing solely in the United States." Accordingly, under the Global Magnitsky Act, individuals who are dual (or more) nationals and companies that are organized under U.S. law(s) and foreign law(s) or exist (e.g., are present, authorized to conduct business) in the United States and one or more foreign jurisdictions, like "foreign persons" completely lacking U.S. status, are apparently subject to sanctions for committing or facilitating sanctionable corrupt acts and human rights abuses. Thus, these "U.S. Persons," when regarded as "foreign persons" under the Global Magnitsky Act, have additional sanctions exposure that would not apply to, for example, individuals holding only U.S. citizenship or companies organized only under U.S. law(s) and existing only in the United States.
From Sergei Magnitsky to Global Magnitsky: United States Asserts Universal Jurisdiction Over Corruption and Human Rights Abuses
As the above description indicates, the Sergei Magnitsky Act targets persons and places tied to specific events that occurred in one country. Moreover, the Sergei Magnitsky Act can be read to have been adopted or operate as an alternative or last recourse for justice and accountability, following Congress' findings that there was a denial of "any justice or legal remedies" to Mr. Magnitsky by "all state bodies of the Russian Federation" and "impunity since his death of state officials." In contrast, the Global Magnitsky Act contains no analogous Congressional findings, nor does it expressly state or imply that it is a last or alternative resort where adequate legal processes to adjudicate corruption or human rights abuses are unavailable in foreign countries where relevant events took place or parties are located, or before foreign tribunals to which relevant states have submitted to jurisdiction. Instead, the Global Magnitsky Act's default position is the applicability of U.S. sanctions (supported by "credible evidence") without the requirement of a jurisdictional nexus with the United States. Accordingly, the Global Magnitsky Act asserts U.S. universal jurisdiction over the corrupt acts and human rights abuses it targets. EO 13818 goes much further.
Business Ethics & Conduct, Global Magnitsky Sanctions, Sanctions
From Sergei Magnitsky to Global Magnitsky: United States Sanctions Corruption and Human Rights Abuses Globally
The financial penalties imposed by the Global Magnitsky Sanctions (and other U.S. sanctions programs) are powerful, as they effectively cut off sanctioned persons from the U.S. financial system and, substantially, U.S. dollar transactions. Given the size and centrality of the U.S. financial system to international commerce and payments, persons without access to U.S. banks and other constituent parts of the U.S. financial system are largely shut out of the international financial system (this assumes, of course, effective enforcement and compliance by U.S. authorities, banks and international financial system participants). Put in context, the United States' Global Magnitsky Act and sanctions program are singular in their force. Other countries have adopted versions of a Magnitsky Act (including Canada, which has imposed sanctions under its law), but none of these other Magnitsky frameworks rival the potential sweep and impact of the United States' Magnitsky framework.
U.S. Magnitsky Sanctions Are a Powerful Weapon Against Corruption and Human Rights Abuse
EO 13818 directly targets foreign government officials and private parties who commit or enable human rights abuses and certain corrupt acts. The Order also employs extraordinary theories of liability. For example, EO 13818 holds current and former "leaders" of foreign entities (government and private) strictly and vicariously liable—and thus sanctionable—for the corrupt acts, during a leader's tenure, of their entities. The Order also imputes the sanctioned status of a blocked private or government entity to its current or former "leaders," if the entity was blocked "as a result of activities related to the leader's or official's tenure." Additionally, EO 13818 treats as a corrupt act the transfer or facilitation of the transfer of corrupt proceeds by current or former foreign government officials and "persons acting for or on their behalf." These three bases for liability, among others, are unique to EO 13818—they are not provided for by the Global Magnitsky Act.
Anti-Corruption, Anti-money laundering, Global Magnitsky Sanctions, Sanctions
Global Magnitsky Sanctions Punish Corruption and Human Rights Abuses Worldwide
Global Magnitsky Sanctions Punish Corruption and Human Rights Abuses Worldwide Magnitsky Laws and Sanctions Series, No. 1 | March 5, 2018 | By Hdeel Abdelhady | Download PDF | Series Part…
Iran Sanctions, National Security Law, Sanctions
Hostility Toward Iran Nuclear Deal May Have Chilling Effect on Legal Transactions Under U.S. Sanctions
The prospect of increasingly hostile policy and legal actions toward Iran may be enough to thwart or make more difficult Iran-related transactions that are (and might remain) legal. Parties planning to engage in such legal Iran-related transactions should take note and, if appropriate, action ahead of any changes in law or adjustments in Iran-related risk-assessments by banks and individual and commercial parties.
Wolfsberg Group Revised Correspondent Banking Due Diligence Questionnaire (2018)
The Wolfsberg Group first announced the release of the CBDDQ in 2017. However, the Group did not make the CBDDQ widely available. After initially announcing the CBDDQ, the Wolfsberg Group held back after deciding that the CBDDQ should be published more widely "once an additional set of materials has been completed . . . in order to limit the ability of third parties to interpret what it is that the Group intended with the DDQ and who it was directed to."
Anti-Corruption, National Security Law, Sanctions
United States Targets Chinese Dominance, Corruption in Africa
Trump Administration's National Security Strategy Promotes a U.S.-Africa Trade-Based "Alternative to China's Extractive Economic Footprint" and Threatens Sanctions and Foreign Aid Penalties for Corrupt Practices and Other Wrongs.
Banking Law & Regulation, Sanctions
Ukraine/Russia Sanctions: OFAC Authorizes Derivatives Linked to Prohibited Debt and Equity Under OFAC Directives 1, 2 or 3
As discussed in an earlier MassPoint Business Update on OFAC Directive 1, it was expected that OFAC would issue, by November 28, 2017, a general license authorizing derivative transactions in prohibited debt and equity (see table below), consistent with the debt maturity limitations imposed by CAATSA. General License 1B does not authorize primary transactions by U.S. persons (wherever located) or in the United States in assets subject to the prohibitions of Directives 1, 2, or 3.
Anti-Corruption, Anti-money laundering, Business Ethics & Conduct, Doing Business in Emerging Markets, Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, Sanctions
Hdeel Abdelhady to Speak on Managing Money Laundering, Trade Sanctions, and Corruption Risks
MassPoint's Founder and Principal, Hdeel Abdelhady, will speak at a program on managing money laundering, trade sanctions, and corruption risks in business. The program, entitled "Know Your Business Partners: A Must to Managing Money Laundering, Trade Sanctions, and Corruption Risks," will take place on November 17, 2017 in Washington, D.C. at the American Bar Association Business Law Section's Fall 2017 Meeting.
Wolfsberg Group Updates Correspondent Banking Due Diligence Questionnaire
The Wolfsberg Group, a group of thirteen global banks, on October 15, 2017 announced its issuance of a "comprehensively" updated Correspondent Banking Due Diligence Questionnaire (the "CBDDQ"). The CBDDQ responds to FATF Recommendation 13 on Correspondent Banking and is the international correspondent banking standard on which the Wolfsberg Group members have "settled", "committed to being early adopters of," and plan to support "with FAQ's and additional awareness raising materials."
Banking Law & Regulation, National Security Law, Sanctions
OFAC DIRECTIVE 1 AS AMENDED SEPTEMBER 29, 2017
As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA), the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) on September 29, 2017 amended and reissued OFAC Directive 1 (Directive 1). As amended, Directive 1 continues to prohibit certain "new" debt, equity, and related transactions involving entities subject to U.S. Sectoral Sanctions targeting Russia's financial services sector. This Business Update discusses the background to and mechanics of Directive 1 as amended and reissued.
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, National Security Law
Banks, Credit Unions and Other Financial Insitutions as Deputized Law Enforcement
The logic and law enforcement value of imposing anti-financial crime obligations on financial intermediaries are clear. Nevertheless, a reassessment is now appropriate, particularly given (1) increasing legal and regulatory demands on financial intermediaries; (2) the exclusion, through "derisking," from the financial system of small and medium businesses (SMEs), nonprofit organizations, money services businesses (MSBs), and correspondent relationship-dependent banks; and, (3) overarching questions as to whether the financial and administrative costs of compliance within the current legal framework—generally or at specific points—yield commensurate law enforcement benefits without unduly harming the legitimate interests of individuals, businesses and other financial system stakeholders.
Anti-money laundering, Banking Law & Regulation, Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, Sanctions
Hdeel Abdelhady Discussed the NYDFS Habib Bank Enforcement Action
MassPoint's Founder and Principal, Hdeel Abdelhady, discussed the legal significance and potential commercial implications of the NYDFS' enforcement action against Habib Bank at a time of correspondent banking derisking.
Anti-Corruption, Anti-money laundering, Doing Business in the United States
FinCEN Expands Geographic Targeting Orders
On August 22, 2017, the Financial Crimes Enforcement Network (FinCEN) issued revised Geographic Targeting Orders (GTOs) designed to combat money laundering and related financial crimes in select U.S. residential real estate markets. The GTOs further expand the scope of GTOs issued in January 2016, expanded in July 2016, and renewed in February 2017. In tandem with the August GTOs, FinCEN issued an Advisory to Financial Institutions and Real Estate Firms and Professionals (the "Advisory") and FAQs.
Doing Business in Emerging Markets, Sanctions
House Bill Would Enhance U.S. States' Iran Sanctions Authority
On July 26, 2017, a bill was introduced in the House that would bolster U.S. states' authority to impose sanctions on parties that engage in certain business with or in Iran. The State Sanctions Against Iranian Terrorism Act, H.R. 3425, would "amend the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 to secure the authority of State and local governments to adopt and enforce measures restricting investment in business enterprises in Iran, and for other purposes."
House Bill Would Establish National Strategy for Combating Terrorism Financing
On July 20, 2017, Representative Ted Budd (R-NC) introduced in the House of Representatives H.R. 3321, the "National Strategy for Combating Terrorist, Underground, and Other Illicit Financing Act." The purpose of H.R. 3321 is to "require the establishment of a national strategy for combating the financing of terrorism and related financial crimes, and for other purposes." As summarized by the House Financial Services Committee, which will meet to markup the bill on July 25, 2017, H.R. 3321 would among other measures "require the President, acting through the Treasury Secretary, to develop and publish a whole-of-government strategy to combat money laundering and terrorist financing."
World Bank Accountability Act of 2017
The stated purpose of the World Bank Accountability Act of 2017 is to "increase accountability, combat corruption, and strengthen management effectiveness at the World Bank." Among other measures, H.R. 3326 would, as summarized by the Financial Services Committee, "withhold a portion of future appropriations for the World Bank until the Treasury Department reports that the World Bank has undertaken reforms to fight corruption, strengthen management accountability, and undermine violent extremism." In addition, the World Bank Accountability Act of 2017 would "authorize the Trump Administration's request for reduced funding to the Bank's International Development Association."
Anti-money laundering, Doing Business in Emerging Markets
Congressional Hearing: Managing Terrorism Financing Risk in Remittances and Money Transfers
The U.S. House of Representatives Financial Services Committee (the "FSC") Terrorism and Illicit Finance Subcommittee will on July 18, 2017 hold a hearing entitled "Managing Terrorism Financing Risk in Remittances and Money Transfers." The FSC memorandum to all of its members states that the "hearing will explore the terrorist and illicit financing risks that are inherent in any form of asset transfer whether through formal banking channels, MSBs, other legitimate remittance networks, or through informal and unregulated value-transfer systems."
Doing Business in the United States, Russia Sanctions, Sanctions
OFAC Directive 1 "New" Financing, Debt, Equity: Explainer
OFAC Directive 1 Explainer: "New" Financing, Debt, Equity In light of the July 30, 2015 addition to the U.S. Sectoral Sanctions list of the Russian Direct Investment Fund and…
Do State Regulators Like the NYDFS Have Authority to Enforce OFAC Sanctions?
the enforcement of OFAC-administered sanctions by a state agency—even against banks by a banking regulator operating in a dual banking system—raises fundamental constitutional and other legal questions. Chief among them is the overarching question of whether U.S. states have authority to directly or effectively enforce OFAC-administered sanctions, particularly independently and prior to enforcement by competent federal authorities—namely OFAC. This question and some of the legal issues and policy and practical considerations appertaining to it are discussed in detail in a forthcoming publication. This document provides a summary preview of some of the key legal issues discussed in that publication. Additional summary previews may be provided separately.
Correspondent Banking and Derisking Update
Ahead of the upcoming G20 meeting, the Financial Stability Board (FSB) published today, July 4, 2017, a progress report on efforts to address the withdrawal of correspondent banking relationships (derisking) and its action plan to assess and address derisking. Among the areas of concern and action items identified by the FSB are remittances and building the capacity of affected respondent bank jurisdictions to effectively identify and counter money laundering, terrorism finance, and other illicit financial activities. Importantly, the FSB has stated that its efforts will focus not just on legislation and rule-making in respondent jurisdictions, but also on the capacity of those jurisdictions to implement and enforce stronger AML/CFT and other anti-financial crime rules.
Anti-Corruption, Anti-money laundering, Doing Business in Emerging Markets, Doing Business in the United States
Sovereign Commercial Enterprises: Anti-Corruption and Confidentiality Risks
State-owned enterprises (SOEs, including sovereign wealth funds) are prominent players in international business. Given their ownership, SOEs have garnered scrutiny for their lack of transparency and heightened anti-corruption and anti-money laundering risk, as have individual SOE executives and other personnel who qualify as Politically Exposed Persons. In connection with commercial activities, SOEs are not protected in most cases by sovereign immunity. Thus, SOEs can, like their privately-owned counterparts, be subject to foreign legal processes. Given the greater scrutiny around SOEs and some of the high profile enforcement actions involving them directly or indirectly (for example, the 1MDB case), anti-corruption and other compliance, as well as good governance and risk management, are essential to avoid legal, commercial, and reputational risk and loss.
Banking Law & Regulation, Doing Business in Emerging Markets, Islamic Banking & Finance, Islamic Law
Dana Gas Says its Sukuk is Unlawful: Issues and Questions
Parsing Dana Gas' Statement that Sukuk is "Unlawful": Shari'ah, UAE Law, and Factual Questions [1] June 18, 2017 | Author: Hdeel Abdelhady* As discussed briefly in this June 16 MassPoint…
Basel Committee Clarifies Guidance on Countering Money Laundering and Terrorism Financing in Correspondent Banking
With respect to foreign correspondent banking, the Guidelines' clarifications are designed to respond to the withdrawal of correspondent banking relationships (derisking) that have adversely affected banks and, in some cases, entire regions. Accordingly, Annex 2 of the Guidelines includes a list of risk factors that "correspondent banks should consider in their risk assessment of money laundering and financing of terrorism associated with correspondent banking."
Anti-Corruption, Doing Business in Emerging Markets
Abu Dhabi Global Market to Offer Foundation Vehicle
Abu Dhabi Global Market (ADGM), the international financial center and free zone located on Al Maryah Island in the UAE capital Abu Dhabi, yesterday opened a public consultation on the ADGM's proposed foundation regime (Consultation Paper No. 3 of 2017 and proposed Foundations Regulations 2017). The development is significant and positive, as the ADGM foundation, as proposed, would be the first-of-its kind in the UAE and particularly helpful for family businesses, philanthropy and wealth management in the UAE and the Middle East more broadly. The foundation model proposed is based on the civil law foundation, as it is an incorporated entity (with independent legal personality) with characteristics analogous to some features of the common law trust.
Doing Business in Emerging Markets, Sanctions, United States China Law and Policy
China's One Belt One Road Could Disrupt U.S. Legal Dominance
The OBOR, even if partially successful, would, as many analysts and commentators have noted, alter the global trade landscape, if not "shake up" the global economic order in place since the end of World War II. Less discussed (except, for example, in this 2015 MassPoint Occasional Note) is one likely secondary effect of the OBOR and other trade and finance initiatives that are not centered on the U.S. dollar or the Bretton Woods system: the likely curtailment of the global reach of U.S. law.
Anti-money laundering, Banking Law & Regulation, Doing Business in the United States, National Security Law
Congressional Hearing on Terrorism Financing Probes Bank Secrecy Act Data Effectiveness, Potential BSA Amendments
On April 27, 2017, I attended a Congressional hearing on "Safeguarding the Financial System from Terrorist Financing," held by the House Committee on Financial Services' Subcommittee on Terrorism and Illicit Finance (the "Subcommittee"). The sole witness was Mr. Jamal El-Hindi, Acting Director of the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury charged with protecting the financial system from money laundering, terrorism financing and other illicit activities. The hearing's purposes were to examine the methods and efficacy of FinCEN data collection, processing and information sharing and whether the Bank Secrecy Act (BSA) and USA PATRIOT Act should be amended to improve FinCEN's anti-money laundering (AML) and counter-terrorism financing (CFT) capacities and performance. In this brief MassPoint update, I highlight BSA data collection and usage numbers and some of the questions and issues that appeared to be of particular interest and/or concern to Congress members in attendance, taking into account the nature and frequency of the questions asked, the tone of questions, and related requests for additional or clarifying information from FinCEN.
Anti-Corruption, Anti-money laundering
Money Laundering and Lawyers' Obligations After the Panama Papers
As Co-Chair of the Middle East Committee of the American Bar Association Section of International Law, MassPoint's Hdeel Abdelhady organized and will moderate a program on lawyers' obligations to detect and report illicit client activity, in particular money laundering. Lawyers in the EU, for example, have been required for years to perform client due diligence and file suspicious activity reports (SARs) in accordance EU anti-money laundering directives. U.S. lawyers have no parallel obligations; however, U.S. lawyers are prohibited by rules of professional conduct from knowingly allowing their services to be used for unlawful purposes. The Financial Action Task Force (FATF) has described the inapplicability to U.S. lawyers of customer due diligence (CDD) and SAR filing requirements as a weak spot in the U.S. anti-money laundering framework. Members of Congress have introduced legislation to apply such obligations to U.S. lawyers, and to require U.S. lawyers to collect and share with law enforcement authorities beneficial ownership information where lawyers directly form companies, trusts, and certain other entities for clients.
Anti-money laundering, Business Ethics & Conduct, Environmental Social Governance (ESG)
Nonfinancial Risk for Banks: Environmental Social and Governance (ESG)
As banks continue to manage regulatory and risk complexity, they should add Environmental, Social, and Governance (ESG) and general business conduct issues to their nonfinancial risk matrices. ESG and business conduct issues—whether or not the subject to legal prescriptions— are no longer ancillary to risk and reputation management. Nor can ESG and business conduct awareness be regarded as merely ornamentation to enhance corporate appearance (or conceal corporate blemishes).
Identifying UAE "Foreign Officials" for Anti-Corruption Compliance Purposes
Companies and other organizations doing business in the UAE or with enterprises owned in part by a UAE Government party at any level (e.g., the federal/union government or a government of one of the country's constituent emirates (e.g., Dubai, Abu Dhabi, Ras al Khaimah), or entities owned in part by any of them, should be aware that under UAE law, the definition of "public official" (i.e., a government official) includes employees and directors of enterprises in which a UAE Government party holds less than a majority ownership stake and does not, formally or effectively, exercise control.
Senate Bill to Combat ISIS Targets "Jurisdictions of Terrorism Financing Concern"
On February 13, 2017, Senator Bob Casey (D-PA) introduced in the Senate the "Stop Terrorist Operational Resources and Money Act" (the "STORM Act"). The purpose of the STORM Act is to "establish a designation for jurisdictions permissive to terrorism financing, to build the capacity of partner nations to investigate, prosecute, and hold accountable terrorist financiers, to impose restrictions on foreign financial institutions that provide financial services for terrorist organizations, and for other purposes." The STORM Act would permit the President to designate a country as a "Jurisdiction of Terrorism Financing Concern" upon determining that "government officials know, or should know, that activities are taking place within the country that substantially finance the operations of, or acts of international terrorism by, foreign terrorist organizations."
Trump's Foreign Policy May Further Strain Foreign Correspondent Banking (Derisking)
The Trump Administration's positions on countering the financing of terrorism were articulated by Treasury Secretary nominee Steven Mnuchin during his confirmation hearings, where he expressed his commitment to working unilaterally and multilaterally to combat terrorism financing (see, for example, hearing segment starting at 55:18). The Administration's interest in strengthening CFT is shared on the other side of Pennsylvania Avenue, where the U.S. House of Representatives' Committee on Financial Services recently released the results of a 2-year investigation of terrorism financing and, among other measures, recommended that the United States adopt a "whole-of-government" strategy to combat terrorism financing.
Business Ethics & Conduct, Critical Resources, Doing Business in the United States, Environmental Social Governance (ESG), Foreign Investment in the United States, National Security Law, Sanctions, United States China Law and Policy
After Election 2016: 5 Legal and Business Issues to Watch in 2017
The dismantling of Obama-era laws and regulations, broader deregulation, and economic and political nationalism were and remain themes of the 2016 U.S. Election and presidential transition period. Donald Trump and members of the incoming Republican-controlled Congress have singled out for repeal or significant modification the Affordable Care Act (aka "Obamacare") and the Dodd-Frank Wall Street Reform and Consumer Protection Act, along with trade, immigration, foreign affairs, and environmental laws, regulations, and policies. If taken, these actions will not only effect legal changes in specific areas, they will create legal and policy voids that may be filled by U.S. states and localities, foreign governments and multilateral and non-governmental organizations, and the private sector. Five legal and business issues and dynamics to watch in 2017 are highlighted here.
Doing Business in the United States, Environmental Social Governance (ESG), Foreign Investment in the United States, National Security Law, Sanctions, United States China Law and Policy
5 Legal and Business Issues to Watch in 2017
Published on January 2, 2016, MassPoint Legal and Strategy Advisory's 5 legal and business issues to watch in 2017, from administrative law (and the Congressional Review Act) to the treatment of foreign investment in the United States to the role of the private sector on environmental, social, and governance issues in light of shifting U.S. policy and legal stances after the 2016 Election.
Anti-Corruption, Anti-money laundering, Doing Business in the United States, MassPoint Legal and Strategy Advisory PLLC, MassPoint News, Sanctions
IRAN AFTER PARTIAL SANCTIONS RELIEF AND U.S. ELECTIONS
MassPoint PLLC, with the American Bar Association Section of International Law and Bryan Cave LLP, are sponsoring a program entitled "Iran After Partial Sanctions Relief and U.S. Elections: Legal, Risk, and Practical Issues for Business." Hdeel Abdelhady, who wrote and organized the program, will serve as moderator.
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, Doing Business in the United States, Sanctions
State Enforcement of OFAC Sanctions Against Banks
Beyond case recitations and optics, the enforcement of OFAC-administered sanctions by a state agency—even against banks by a banking regulator operating in a dual banking system—raises fundamental constitutional and other legal questions. Chief among them is the overarching question of whether U.S. states have authority to directly or effectively enforce OFAC-administered sanctions, particularly independently and prior to enforcement by competent federal authorities—namely OFAC. This question and some of the legal issues and policy and practical considerations appertaining to it are discussed in detail in a forthcoming publication. This document provides a summary preview of some of the key legal issues discussed in that publication. Additional summary previews may be provided separately.
Doing Business in the United States, National Security Law, Sanctions
Do State Regulators Have Authority to Enforce OFAC Sanctions?
Insolvency Regimes for Islamic Banks: Regulatory Prerogative and Process Design
Specialized Insolvency Regimes for Islamic Banks: Regulatory Prerogative and Process Design Author: Hdeel Abdelhady Original Publication: World Bank Legal Review, Volume 5 Abstract As Islamic banks grow in size…
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, Doing Business in Emerging Markets
Politically Exposed Persons and State-Owned Enterprises: Anticorruption – AML Nexus
Recent investigations of financial institutions for "corrupt" hiring of foreign officials' family members highlight links between anticorruption and AML compliance and enforcement. Financial institutions dealing with politically exposed persons and state-owned enterprises should leverage AML expertise to bolster anticorruption compliance.
Anti-money laundering, Doing Business in Emerging Markets, Sanctions
Non-Dollar Trade Could Curtail the Global Reach of U.S. Sanctions and Other Laws
American economic and financial heft facilitates the extraterritorial reach of U.S. law. For example, global transactions that are denominated in U.S. dollars and processed through the U.S. financial system "touch" the United States, come within its jurisdiction and create a jurisdictional nexus to foreign parties, property and events associated with those transactions.
Anti-Corruption, Banking Law & Regulation, Doing Business in Emerging Markets
BNY Mellon to Pay $14.8 Million to Settle FCPA Corrupt Hiring Charges
BNY's internships for sovereign wealth fund officials were bribes. Key SEC findings and takeaways for compliance.
U.S. Sectoral Sanctions Targeting Russian Financial Services: OFAC Directive 1
Among those added to the SSIL on July 30 are the Russian Direct Investment Fund (RDIF) and other entities identified by OFAC as being owned 50% or more by Russian state development bank Vnesheconombank (VEB). VEB itself was added to the SSIL on July 16, 2014, the same day on which OFAC first issued Directive 1, the relevant financial services sanctions implementing measure discussed in detail below (as applicable to the VEB-owned entitles and generally). The July 30 action is significant more for its likely practical impact, rather than its immediate legal meaning. This is so because the relevant VEB-owned entities, while not previously listed on the SSIL, have nevertheless been subject to Sectoral Sanctions since July 16, 2014.[iii] The VEB's sanctioned status as of July 16, 2014 was imputed to its owned entities on the same day by operation of OFAC's "50% Rule," which attaches to entities owned 50% or more by one or more SSIL entities (individually or in the aggregate) the sanctions status of their owner(s), even if such owned entities are not separately listed on the SSIL. The 50% Rule significantly expands the potential scope of Sectoral Sanctions and corresponding compliance obligations. Effectively, the 50% Rule requires parties to determine, at every link in the ownership chain (vertically and horizontally), whether one or more SSIL entities (alone or in the aggregate) directly or indirectly owns 50% or more of a relevant entity. This can be particularly burdensome where corporate structures are complex and/or opaque.
[i] Directive 1 (amended) and Directive 1 (original). [ii] Executive Order No. 13662. See also 31 C.F.R. § 589.312. [iii] No. 371, Sectoral Sanctions FAQs. [iv] Id. [v] No.…
OFAC Directive 1: Financing, Debt & Equity Prohibitions
On July 30, 2015, the Office of Foreign Assets Control (OFAC) made explicit the sanctioned status of certain entities operating in Russia's financial services sector by adding them to the Sectoral Sanctions Identifications List (SSIL).The SSIL identifies parties subject to U.S. Sanctions targeting specific sectors of the Russian economy (Sectoral Sanctions) within the framework of Ukraine/Russia-related sanctions adopted in response to events in Ukraine. Currently Russia's financial services, defense, and energy sectors are targeted. Nevertheless, they may encounter legal, commercial, or reputational risk in the context of current or planned business with or involving a sanctioned entity, whether listed on the SSIL (or another sanctions list) or sanctioned as a matter of law (such as under the 50% Rule).
Anti-Corruption, Anti-money laundering, Banking Law & Regulation, Doing Business in Emerging Markets, Sanctions
Non-Dollar Trade May Stem Extraterritorial Reach of U.S. Law
The United States is singularly positioned (and willing) to leverage its economic and financial strength to enforce its laws and policies globally. American economic and financial heft facilitates the extraterritorial reach of U.S. law. Global transactions that are denominated in U.S. dollars and processed through the U.S. financial system "touch" the United States, come within its jurisdiction and create a jurisdictional nexus to foreign parties, property and events associated with those transactions.The rise of the renminbi and non-dollar trade and finance channels such as One Belt One Road, the BRICs Bank, and the Asian Infrastructure Investment Bank could curtail the global, extraterritorial reach of U.S. law.
Cross Compliance for Financial Institutions: Anti-Corruption – Anti-Money Laundering Nexus
Enforcement authorities in the US and Asia reportedly are investigating financial institutions for potentially corrupt employment and business relationships with family members of government officials. The investigations underscore policy links between anti-corruption and anti-money laundering regimes where dealings with Politically Exposed Persons (PEPs) are involved. This article, published by Hdeel Abdelhady in Butterworths Journal of Banking and Financial Law, briefly discusses the pending investigations and the anti-corruption-AML policy nexus, and suggests, with respect to PEPs and more generally, that financial institutions facilitate fluidity in their compliance programs to allow for the sharing of information and adaptation of compliance protocols across (sometimes impermeable) internal functional and disciplinary lines.
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Hello lovelies! I have another haul to share with you today, this time from ebay store iamlove-shop!
Mini-review of ebay user iamlove-shop: This shop has a large selection of Korean cosmetics and beauty products and the prices are very reasonable. The package arrive about three weeks after I ordered it and was wrapped carefully in bubble wrap. Nothing was damaged in transit, and there were tons of samples included in my order. All in all an awesome experience from iamlove-shop.


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Home Slider, News, Press Releases, Publications, VOX-Pol Publications
Research Finds Differential Emphasis in Islamic State Propaganda
VOX-Pol has released its latest report in the VOX-Pol publication series, titled A Tale Of Two Caliphates: Comparing the Islamic State's Internal and External Messaging Priorities, co-authored by Dr. Dounia Mahlouly and Charlie Winter.
In recent years, the media department of the self-proclaimed Islamic State has proven itself to be highly adept at strategic communication. While much research has gone into the group's digital and online capabilities, there remains a significant gap in the knowledge regarding its in-country propaganda operations and objectives.
In recognition of this, the following research paper approaches the issue from a different angle, attempting to better understand how and why the group communicates its brand through the lens of two publications – al-Naba', its Arabic-language newspaper, which appears to be designed primarily for offline dissemination in the caliphate itself, and Rumiyah, its foreign-language electronic magazine, which has only ever appeared online. Using content analysis to identify and compare each publication's internal (local) and external (global) media priorities over the four-month period between September and December 2016, we develop an empirical evaluation of the group's recent forays into targeted outreach.
The Islamic State's publication priorities at the end of 2016 were largely bifurcated—its propagandists seemed to want different
responses from different audiences, and Rumiyah and al-Naba' were particularly demonstrative of this.
Structurally, the publications bore only partial resemblance to each other, with Rumiyah privileging lengthier, more discursive ideological content and al-Naba' primarily tending to preference briefer tactical news items.
The publications were also distinct thematically: Rumiyah's content was significantly more abstract – that is, weighted towards complex political, social and theological issues – than that of al-Naba', which shed much more light on present-day military matters than anything else.
Al-Naba''s conception of jihad was distinctly more pragmatic than that of Rumiyah – it focused on real-world concerns rather than ideology, something that could point towards the differing motivations of the Islamic State's in- and ex-theatre supporters.
There were significant geographic discrepancies between the two publications, with Rumiyah spending more time discussing events and operations external to Syria and Iraq than al-Naba'. This was most apparent in the context of the battle for Mosul, which was entirely absent from the pages of Rumiyah, and regularly front-page news in al-Naba'.
It appears that each publication was carefully tailored to suit its primary consumer audience – in Rumiyah's case, this was the Islamic State's diffuse archipelago of global supporters, and in the context of al-Naba', this was, and continues to be, its in-country rank-and-file.
Accessing VOX-Pol Reports
All VOX-Pol reports are open-access. This report is available for download here. If you would like to receive a hardcopy of the report, please email info@voxpol.eu with your request.
in Home Slider, News, Press Releases, Publications, VOX-Pol Publications ISIS, ISIS Media, Islamic State, Jihadist Propaganda
Fighting ISIS on Facebook - Breaking the ISIS Brand Counter-Narratives Project
TTP's Online Women's Magazine Has a Different Message for Their Female Jihadi Audience Than Rumiyah

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How can Iran bypass US sanctions?
With the second round of sanctions against Iran, US President Donald Trump's threat to impose the "toughest ever" punitive measures against the Islamic Republic is in full force, a reversal from his predecessor Barack Obama's rapprochment towards Tehran.
In August, sanctions targeted Iran's aviation industry, currency and even carpets. Now, except for a few countries, the rest of the world is cut off from Iran's oil and gas market as well as its financial system.
Iran remains a signatory to the 2015 multilateral nuclear deal and UN inspectors said Tehran continues to adhere to its obligations. Trump unilaterally abandoned the agreement in May, paving the way for the imposition of US sanctions amid international opposition.
Who will be worst hit by U.S. sanctions on Iran?
Now that the US sanctions are in place, experts said the two old adversaries would be engaged in a cat and mouse game, with Washington trying to enforce Trump's order as rigorously as it could, and Tehran finding creative ways to bypass it.
US Secretary of State Mike Pompeo himself acknowledged that it would be "unsurprising" if Iran would try to bypass the sanctions.
Ali Sarzaeem, an economics advisor at the Center for Strategic Studies under the office of President Hassan Rouhani, said that there are several measures being considered to counter the US restrictions.
"The US is doing whatever it can to punish Iran, and we are doing whatever we can do to confront them," Sarzaeem, who teaches at Tehran's Allameh Tabataba'i University, told Al Jazeera.
So what steps could Iran take to bypass the US sanctions?
Iran has kept doing business with other countries amid sanctions through waivers obtained by its trading partners.
On Monday, Pompeo named the countries granted waivers to buy Iranian oil and gas after November 5: China, India, Italy, Japan, Greece, South Korea, Taiwan and Turkey.
Pompeo did not say how long the waivers will last, but said they were granted to ensure oil prices are not destabilised if supply from Iran is abruptly removed from the international market.
Pompeo said that since Trump announced the sanctions in May, more than a million barrels of Iranian oil were removed from the market, and that Tehran lost more than $2.5bn in oil revenues.
Trump boasted he will drive down Iran's revenue to zero. But Iran said the granting of US waivers is a win for Tehran, as it allows it to sell oil beyond the deadline.
In September, Iran sold between 1.7 million and 1.9 million bpd of crude oil, according to a CNBC analysis. That number came down to 800,000 bpd from May, when the sanctions were announced. But the loss in volume was partly offset by the rise in the oil price.
On September 24, the European Union (EU) announced that it is setting up a new mechanism, the Special Purpose Vehicle (SPV).
EU Foreign Policy Chief Federica Mogherini said the SPV "will allow European companies to continue to trade with Iran in accordance with EU law and could be open to other partners in the world".
EU, alongside the United Kingdom, Russia, Germany, France, China, the US and Iran were the original signatories of the 2015 deal, which is also known as the Joint Comprehensive Plan of Action (JCPOA).
Europe's decision to create the SPV was seen as an act of defiance against Trump.
Essentially, the SPV acts as a clearing house handling payments from European companies to and from Iran, while avoiding the US sanctions that prohibit direct payment through the regular payment system.
For example, if a European energy company buys oil and gas from Iran, the payments are directed to the SPV. In turn, Iran will use the payments deposited in the SPV to buy permitted items from Europe.
It is not yet clear how the final SPV structure would like. Whether or not European companies would avail it also remains a question. Many European companies, such as Total, have profitable operations in the US, and they could get slapped with US sanctions if they insist on trading with Iran.
On Monday, Iran's Foreign MInistry spokesman Bahram Qassemi counseled patience in the implementation of the SPV, but he also said the establishment of the new financial mechanism is "complicated and time-consuming".
The SPV is still seen as another victory in Iran as it indicates Europe's willingness to stand up to Trump.
In August, the EU also updated the Blocking Statute, thereby shielding European companies from Trump's sanction, while allowing them to continue operating in Iran.
It also allows companies to recover damages arising from punitive sanctions, in this case, from the US.
The law also forbids EU persons from complying with those kind of sanctions, unless exceptionally authorised by the European Commission.
While it could work for small businesses with no links to the US, the statute could have limited use in Iran, particularly among major European companies with global operations. Those companies are automatically exposed to possible US sanctions in the event they deal with Iran.
In late October, Iran announced that it has started offering oil for sale via its stock exchange, selling as much as 280,000 barrels of crude oil just minutes after the opening bell.
The idea of selling oil in the stock market first came up in 2000 during the previous period of sanctions, but is only implemented now.
According to Tasnim news agency, 280,000 barrels were traded in the Iran Energy Exchange (IRENEX) at $74.85 per barrel. On the first day of trading, a total of one million barrels of crude oil were eventually sold.
Essentially, private buyers from within Iran or abroad buy the crude oil. In turn, the buyers can sell the same product to the world market with less traceability.
The US Treausury's Office of Foreign Assets Control (OFAC) maintains a list of sanctioned companies and individuals linked to the Iran case. But a new company not listed by OFAC can "legally" buy oil from Iran.
Mohammad Eslami, a Tehran-based sanctions experts said, that there are still other measures that the Iranian government is taking to circumvent the US sanctions.
Tehran is reluctant to discuss those measures openly as it does not want to compromise them, he said.
"All these structures, that the Iranians have built to confront these new sanctions, are unofficial," said Eslami before adding that the measures included currency swap with other countries, and even crypto currency trading, adding that some entities are "already using it".
Iran's partners like Russia and China also "would not be willing to talk about the alternatives".
Russia, which has not been included in the US waiver, has denounced the sanctions, terming them "illegal". There have been suggestions that Moscow would help Tehran bypass the sanctions by buying Iranian oil, then reselling them in refined form to Europe.
Pompeo had already issued a warning, saying the Trump administration "is fully prepared to do all that we can" to prevent efforts to bypass the sanctions.
Trump's new sanction would face more complexities compared to the time of the Obama administration, said Eslami.
He said that while Trump's sanctions are "more measured", the US president failed to establish a global consensus against Iran, as he "could not establish powerful group of supporters for his policy".
Can the EU bypass US sanctions on Iran?


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