APC Compliance and Regulatory Services’ Post

Do you know what you need for the G7 price cap update and the per-voyage attestation requirement? Simon Ring, Windward’s Senior Commercial Director, explains and also delves into 2024's sanctions reality, with four important steps to take. Proactive compliance, strategic partnerships, and two more — get the four steps to thriving in this ever-changing environment. 👇 #MaritimeCompliance #Sanctions #PriceCap

📣 Treasury / OFAC Issues License for Wind Down of Transactions with Newly Blocked Russian Entities On June 12, 2024, the Office of Foreign Assets Control (OFAC) issued General License No. 98 under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587). ✅ This license permits the wind down of transactions involving specific blocked entities, including Aviatech FZC, Joint Stock Company Goznak, and Limited Liability Company Elga, until 12:01 a.m. EDT on July 27, 2024. Transactions must comply with payment restrictions into blocked accounts. ❌ The license excludes activities prohibited under Directives 2 and 4 of E.O. 14024, such as those related to Russian financial institutions and central banking authorities. Original source 👉: https://lnkd.in/g79nW6fc #USsanctions #sanctionsupdate #sanctionscompliance #OFAC #GeneralLicense98 #RussiaSanctions #WindDown #BlockedEntities #ExecutiveOrder14024

"Singapore on Tuesday (Feb 6) passed amendments to ... the Prevention of Proliferation Financing and Other Matters Bill, would allow Singapore to adhere to updated requirements set out by the Financial Action Task Force (FATF), a global money laundering and terrorism financing watchdog... the Bill covered changes to four Acts, namely the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act, the Moneylenders Act, the Pawnbrokers Act and the Legal Profession Act. The Bill proposed updating the regulatory regimes of these sectors and requiring businesses or persons covered by the Acts to implement adequate measures to combat proliferation financing. Examples of the measures include performing risk assessment, as well as developing and implementing internal policies, procedures and controls... There were further changes to the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act to strengthen the sector’s regulatory regime." Tang See Kit, Singapore passes Bill to strengthen laws against financing of weapons of mass destruction—The tightening of controls over proliferation financing covers several business activities, namely dealing in precious stones and metals, moneylending, pawnbroking and providing legal services, 𝘊𝘩𝘢𝘯𝘯𝘦𝘭 𝘕𝘦𝘸𝘴 𝘈𝘴𝘪𝘢, 6 February 2024, https://lnkd.in/gPMpDR5G

Aegis FinServ Corp™ #Financial & #Business #Intelligence update our #SubscriptionService Clients with this #OFAC #Sanctions License Update. Russian Harmful Foreign Activities Sanctions Regulations 31 CFR part 587 GENERAL LICENSE NO. 8I Authorizing Transactions Related to Energy (a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to energy are authorized, through 12:01 a.m. eastern daylight time, November 1, 2024: (1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie; (3) Sovcombank Open Joint Stock Company; (4) Public Joint Stock Company Sberbank of Russia; (5) VTB Bank Public Joint Stock Company; (6) Joint Stock Company Alfa-Bank; (7) Public Joint Stock Company Rosbank; (8) Bank Zenit Public Joint Stock Company; (9) Bank Saint-Petersburg Public Joint Stock Company; (10) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (11) the Central Bank of the Russian Federation. The Florida Bar Florida Bankers Association Florida Mortgage Bankers https://lnkd.in/dYstAPm2

As the Ukraine conflict intensifies, so does support from the west. The leaders of the G7 agreed in principle to issue $50 billion in loans for Ukraine that are backed by the profits of frozen Russian sovereign assets. A big move. Managing risk (including sanctions compliance) in a complex geopolitical landscape is more crucial than ever. It’s complicated with beneficial ownership being opaque. We make this simple with our pre-screening and proactive monitoring for sanctions compliance, providing a 360-degree view of sanctions-related risks. Our offerings ensure compliance, provide comprehensive coverage of sanctions risk, and enhance risk management processes. How are you managing your sanctions risk? #risk #sanctions #tprm

OverRuled OFAC Insights – 2024/1 Buried in the factual portion of OFAC’s July 26, 2024 settlement agreement (https://lnkd.in/e6F-ZyeU) is the following statement: “U.S. persons are permitted to deal in debt with a maturity period longer than the applicable period outlined in Directive 1 if the relevant contract was established prior to the sanctions effective date(s) and was not modified on or after the sanctions effective date(s).” This appears to be the first time – ten years since the issuance of the first “new debt” prohibition – that OFAC has spoken publicly to the status of “pre-sanctions” contracts as it relates to the “new debt” prohibition (apart from certain FAQs dealing specifically with long-term credit facilities). While the statement quoted above only implies as much, OFAC’s longstanding position on the matter—and one memorialized in an unpublished guidance letter issued in the Venezuela context and available only on OverRuled—appears to be that “post-sanctions” invoices issued pursuant to “pre-sanctions” contracts for ordinary goods and services are not considered “new debt” as long as the relevant contract has not been modified since the effective date of the relevant “new debt” prohibition. Follow @OverRuled for additional insights like this and other exclusive content. Email subscriptions@overruled.com for information on how to subscribe.

Aegis FinServ Corp™ #Financial & #Business #Intelligence update our #SubscriptionService Clients with this #OFAC #Sanctions License Update. Russian Harmful Foreign Activities Sanctions Regulations 31 CFR part 587 GENERAL LICENSE NO. 8I Authorizing Transactions Related to Energy (a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to energy are authorized, through 12:01 a.m. eastern daylight time, November 1, 2024: (1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie; (3) Sovcombank Open Joint Stock Company; (4) Public Joint Stock Company Sberbank of Russia; (5) VTB Bank Public Joint Stock Company; (6) Joint Stock Company Alfa-Bank; (7) Public Joint Stock Company Rosbank; (8) Bank Zenit Public Joint Stock Company; (9) Bank Saint-Petersburg Public Joint Stock Company; (10) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (11) the Central Bank of the Russian Federation. https://lnkd.in/dYstAPm2

Aegis FinServ Corp™ #Financial & #Business #Intelligence update our #SubscriptionService Clients with this #OFAC #Sanctions License Update. Russian Harmful Foreign Activities Sanctions Regulations 31 CFR part 587 GENERAL LICENSE NO. 8I Authorizing Transactions Related to Energy (a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to energy are authorized, through 12:01 a.m. eastern daylight time, November 1, 2024: (1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie; (3) Sovcombank Open Joint Stock Company; (4) Public Joint Stock Company Sberbank of Russia; (5) VTB Bank Public Joint Stock Company; (6) Joint Stock Company Alfa-Bank; (7) Public Joint Stock Company Rosbank; (8) Bank Zenit Public Joint Stock Company; (9) Bank Saint-Petersburg Public Joint Stock Company; (10) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (11) the Central Bank of the Russian Federation. https://lnkd.in/dYstAPm2

"New Reporting Requirement. Commencing August 2, 2024, or within 10 days of the detection of Russian sovereign assets, financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, are required to provide notice to OFAC. The new reporting obligation falls on certain financial institutions identified in the Bank Secrecy Act. This includes banks and thrifts, trust companies, the U.S. branches and agencies of foreign banks, credit unions, securities and commodities broker-dealers, investment companies, insurers and currency exchangers. Reporting, as noted above, is required as to Russian sovereign assets, regardless of whether such asset is blocked. That term includes: funds and other property of the Russian Central Bank, the Russian National Wealth Fund and the Russian Ministry of Finance and any other funds or other property owned by the Government of the Russian Federation, including by any subdivision, agency or instrumentality thereof (which term appears to encompass assets of Russian state-owned enterprises, although the OFAC reporting requirement does not address this question squarely)." https://lnkd.in/e8xfBiGs

What countries are high risk for proliferation financing? Understand the process of determining geographic risk with our country scoring methodology. Every business in the regulated sector, from financial services to law firms and estate agencies, is obligated under the Money Laundering Regulations to undertake a proliferation financing risk assessment. A key element is understanding the geographic risks different countries play in PF, and putting in place mitigation measures to protect your firm. https://lnkd.in/dNCdWYrm