Global Sanctions Monthly Update
Our Global Sanctions Monthly Update is a 40-minute presentation designed to keep compliance professionals informed of essential developments in the ever-dynamic world of sanctions. These updates will alert our global community to key changes to sanctions regimes, as well as offer a synopsis of relevant geopolitical developments and proposed legislation. Each includes a general update, geo-political update, regulatory update, and a spotlight issue. This monthly update will help you understand the trends and be able to prepare for what may be coming.
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International Efforts to Counter Sanctions Evasion and Wider Updates
Released in April 2023.
Justine and Sam are joined by the newest member of ACAMS’ Thought Leadership team – Senior Director for Anti-Money Laundering, Craig Timm. Craig succinctly summarizes US Department of Justice actions on Russia since the invasion of Ukraine, highlighting key actions and how approaches are evolving. Craig also provides comments on the recent US Supreme Court judgement concerning Halkbank. Beyond this, the panel discuss the potential EU 11th sanctions package on Russia, recent designations against evasion enablers, and a raft of wider sanctions developments over the past month.
EU 10th Package, Updated OFSI Guidance, and Wider Sanctions Evasion Developments
Released in March 2023.
Justine, Sam and George are joined by Sven Bates, Baker McKenzie. Sven talks us through the EU 10th package of sanctions and what the changes mean for compliance professionals, as well as looking at UK developments – in particular, OFSI’s updated guidance on factors to consider when determining ownership and control. We also discuss Russia’s shadow fleet and wider efforts to counter sanctions evasion and strengthen enforcement, as well as wider-at-a-glance updates from the past month.
Russia Sanctions Updates, Syria Licensing Considerations, and Ransomware Developments
Released in February 2023.
Justine and Sam are joined by David Mortlock, Willkie Farr & Gallagher. David talks us through the state of play for moves to seize frozen Russian assets, including where financial institutions should be focusing their attention, as well as setting out the key questions from the February 5 Russian oil price cap. We also discuss the proposed EU 10th sanctions package, the humanitarian catastrophe in Syria and Türkiye and related licensing developments and considerations, as well as recent ransomware designations and the UK’s Ransomware Sanctions Guidance.
The EU 9th Sanctions Package, Oil Price Cap Updates, and the NDAA 2023
Released in January 2023.
Justine and Sam are joined by Victoria Turner, Principal Associate at Eversheds Sutherland, as well as ACAMS global subject-matter expert George Voloshin. Victoria talks us through the EU 9th sanctions package, setting out what’s contained and outlining key compliance considerations, as well as looking ahead to what we may see next from the EU. George talks us through the latest developments for the oil price cap, including its impact on the Russian economy and countermeasures being undertaken by the Russian government. We also discuss recent US legislation, humanitarian exceptions changes, and wider at-a-glance updates.
Oil Price Cap Developments & UN Sanctions Humanitarian Exemption
Released in December 2022.
Justine and Sam are joined by ACAMS global subject-matter expert George Voloshin. George talks us through G7 oil price cap developments over the past month, setting out some of the key legislation we’ve seen, compliance considerations, and comparing and contrasting across Price Cap Coalition members. We also discuss the United Nations Security Council’s humanitarian carve-out, the EU proposed 9th Russia sanctions package, and global human rights sanctions developments.
US Congressional Midterms & the EU 8th Sanctions Package on Russia
Released in Nov 2022.
Justine and Sam are joined by Matt Zweig, FDD Action, and Jan Dunin-Wasowicz, Hughes Hubbard and Reed. Matt talks us through the complexities of the recent US midterm elections, and the potential sanctions implications that could result from House and Senate majorities as well as key committee appointments. Jan takes a deep dive into the measures introduced within the EU’s 8th package of restrictive measures on Russia, highlighting key differences and looking ahead to what may be on the horizon. Justine and Sam also talk to wider sanctions updates, including with regards to Iran, China, Ransomware, and Haiti.
Special Edition (Live) with US Treasury on Russian Oil Price Caps
Released in Oct 2022.
For this special edition of our sanctions monthly update, we were joined live by US Treasury officials Elizabeth Rosenberg, Assistant Secretary for Terrorist Financing and Financial Crimes, and Andrea Gacki, Director of OFAC. The session addressed the US Treasury’s efforts to advance price cap policy, discuss the policy’s goals, governance, and implementation considerations. This session also featured a live Q&A.
Russian Oil Price Cap and Ongoing Crypto-Sanctions Complexities
Released in Sep 2022.
Justine and Sam are joined by ACAMS colleagues George Voloshin and Joby Carpenter. George talks us through proposals for a price cap on Russian crude oil, discussing how this might work in practice, key regulatory frameworks, and implications for industry. Joby gives us an update on the ever-changing world of cryptocurrency, specifically recent OFSI Guidance as well as ongoing Tornado Cash developments – including recently issued FAQs. Justine and Sam also talk to wider sanctions updates, including with regards to Myanmar, Belarus and Cyber.
Key Russia Sanctions Developments and Crypto-Sanctions Updates
Released in Aug 2022.
Justine and Sam are joined by Rachel Fiorill, Morrison & Foerster, as well as new ACAMS colleague George Voloshin (who regular listeners will know well). Amid a Russia sanctions landscape that continues to be phenomenally busy, Rachel talks us through the key US General License developments over the past month and explains the resulting implications. George also talks us through the evolution of oligarch sanctions, and what this means for efforts to evade sanctions. We also discuss the EU’s 7th sanctions package, China developments, and crypto-sanctions developments – in particular the designation of Tornado Cash.
Sanctions Monthly Update: Ongoing Russia Sanctions Developments
Released in Jul 2022.
Justine and Sam are joined by Paige Berges, Ropes & Gray, and Dr. Maria Shagina, the International Institute for Strategic Studies. Paige and Maria talk us through a number of key recent updates in the Russian sanctions space, including with regard to the state of play of Russian energy exports, the EU 6th round of sanctions (and a potential 7th round), changes to UK sanctions enforcement, banning of Russian gold imports, and moves to confiscated sanctioned resources to support the reconstruction of Ukraine.
Sanctions Monthly Update: Russia-related Export Controls and Bank Account Deposit Restrictions
Released in May 2022.
Justine Walker and Sam Cousins are joined by Melissa Duffy, Fenwick and West, and Zia Ullah, Eversheds. Melissa talks us through the recent raft of export controls implemented on Russia, what these mean, and how industry is meeting the associated challenges. Zia provides an insight on bank account/deposit limit restrictions imposed on Russian and Belarusian nationals, and outlines some key considerations and questions for the sanctions compliance community. Justine and Sam also provide an update on some of the wider Russia-related developments we’ve seen over the past month.
Ongoing Russia Sanctions Considerations
Released in April 2022.
This update follows March’s Russia Special Edition, in which we are again joined by Nick Turner and George Voloshin (as well as ACAMS colleague Joby Carpenter) to talk about Russia sanctions challenges and ongoing key considerations. Our panelists discuss a number of aspects, including ownership and control, contract clauses, energy restrictions, export controls, luxury goods, and cryptocurrency.
Russia Special Edition
Released in March 2022.
March’s update is a special episode focused solely on Russia, and marks the first activity in ACAMS’ rapid-response initiative to the Russia-Ukraine crisis. Justine Walker and Sam Cousins from ACAMS are joined by Nick Turner, Steptoe & Johnson (Hong Kong) and George Voloshin, Aperio Intelligence, to talk about the current state of play on Russia sanctions and assess the phenomenal amount of actions we have seen undertaken in the past week. Our panelists discuss a wide range of aspects in the rapidly evolving Russia sanctions landscape, including the targeting of the Russian Central Bank, key licenses and exemptions, the major expansion of personal asset freezes, efforts to target Russian wealth, anticipated SWIFT disconnection, embargoes and export controls, energy, transport and aviation, and the potential for secondary sanctions.
2nd Annual ACAMS Global Sanctions Space Summit Recap
Released in February 2022.
As diplomatic tensions continued to rise over the international standoff at Ukraine’s border, the 2nd Annual ACAMS Global Sanctions Space Summit opened earlier this month with a keynote speech by the White House National Security Council’s Peter Harrell on the potential use of economic and trade restrictions to impose “severe costs on Russia’s economy” in the event of an invasion. The summit, which featured a live discussion that served as a replacement for the February Monthly Sanctions Update, addressed a broad array of compliance topics, with insights from high-level representatives of the United Nations, World Bank, European Commission, OFAC, OFSI, and many of the world’s largest financial institutions.
Russia State of Play, Afghanistan Humanitarian Considerations, and US-China Legislative Developments
Released in January 2022.
January’s update features a spotlight discussion on the ongoing high-level talks concerning the build-up at the Russia-Ukraine border, including possible economic responses we could see. Panelists also discuss the situation in Afghanistan, including UNSCR 2615 and recent OFAC General Licenses, as well as the Uyghur Forced Labor Prevention Act. Wider updates include human rights and corruption, proliferation finance, the European Commission’s consultation on the Blocking Statute, and changes to the OFSI sanctions list, alongside wider updates.
China, Belarus and Russia
Released in December 2021.
December’s update features a spotlight discussion on recent China/Hong Kong SAR updates, such as changes to the BIS list, military supply chain focus, US legislative developments, and the recent penalties imposed by the Hong Kong Monetary Authority. Panelists also discuss the latest coordinated Belarus sanctions measures, what to watch with regards to Ukraine and Russia developments, as well as key human rights, corruption and cyber sanctions developments.
US Sanctions Policy Review, Cyber Updates, and Libya
Released in November 2021.
November’s update features a spotlight discussion on the recently published U.S. Sanctions Policy Review, including examination of key findings and how the composition of U.S. sanctions has changed. Panelists also discuss cyber developments - such as on cryptocurrency and ransomware – as well as providing an update by way of Libya, including a summary of recent developments and future challenges.
Russia, Proliferation Financing and Ransomware
Released in October 2021.
October’s update examines recent country-regime updates, particularly Russia, as well as providing a summary of wider global sanctions developments. It also focuses on Proliferation Finance, specifically the UK’s PF National Risk Assessment and the UN Panel of Experts report on North Korea, as well as what’s been happening in the ransomware space.
Belarus and FATF’s PF Guidance
Released in September 2021.
This update examines recent country-regime changes, specifically Belarus and Russia, as well as providing a summary of wider global sanctions developments. It also focuses on the FATF’s Proliferation Finance Guidance, in addition to the nexus of ransomware and sanctions compliance.
Monthly Update: Supply Chain Due Diligence Considerations & Nord Stream 2
Released in August 2021.
Alongside country-regime updates and wider sanctions developments, August’s update examines supply chain due diligence considerations and key challenges, particularly in the context of recent Advisories and Guidance issues by regulators. It also focuses on the latest developments concerning the Nord Stream 2 pipeline and remaining questions going forward.
Monthly Update: China and Belarus Developments
Released in July 2021.
Provides an update on the latest China sanctions developments, such as Executive Order 14032 and the new CMIC list, China’s Anti-Foreign Sanctions Law, and Xinjiang-related developments. The latest round of EU sanctions on Belarus, including implications and key compliance considerations, are also covered.
Monthly Update: Post-Brexit Sanctions: 6-Month Review
Released in June 2021.
Includes a 6-month-on review of sanctions post-Brexit, with key differences between the UK and EU regimes, recent developments on the EU Blocking Regulation, and implications of the latest round of designations against Myanmar and the governor of the Central Bank.
Monthly Update: Russia and FATF's PF Guidance
Released in May 2021.
Includes a focus on the recent Russia sanctions, such as the significance of restrictions on Russian sovereign debt, as well as wider China and Myanmar developments. Furthermore, it examined the FATF Proliferation Finance Draft Guidance, ACAMS’ submission, and areas for further public/private dialogue.
Monthly Update: China and Myanmar
Released in April 2021.
April’s edition provides an update on rapidly changing developments with regards to China – such as the recent Xinjiang-related sanctions and countersanctions - and includes a deep-dive into Myanmar sanctions and the business risk environment.
Monthly Update: Yemen
Released in March 2021.
Includes examining recent Russia sanctions developments, such as those relating to the Nord Stream 2 pipeline, as well as a spotlight discussion on the terrorist financing-sanctions-risk context in Yemen.
Monthly Update: Sudan Part II
Released in February 2021.
Includes a spotlight on recent developments concerning Sudan, as well as a geopolitical risk update on China/Hong Kong SAR developments – including aspects such as China’s blocking regulation.
Monthly Update: Brexit Lists and CCMC sanctions
Released in January 2021.
Examined Brexit-related changes and alignment for sanctions screening lists, as well as a spotlight discussion on Chinese Military Companies sanctions.
Monthly Update: Brexit
Released in December 2020.
Featured a spotlight discussion on UK-sanctions post Brexit.
Monthly Update: Energy Sanctions and Waivers
Released in November 2020.
Examined recent China/Hong Kong SAR developments, including the publication of the US State Department list of “foreign persons” under Section 5(a) of the Hong Kong Autonomy Act (HKAA) and issuance of related FAQs, and features a spotlight discussion on energy sanctions and waivers.
Monthly Update: Supply Chain Sanctions Risks
Released in October 2020.
Examined China/Hong Kong SAR developments, including the issuance of Global Magnitsky General License 2A, and discussed navigating supply chain sanctions risks in the context of COVID-19.
Monthly Update: Iran
Released in September 2020.
Featured a spotlight discussion on current deliberations surrounding UN snapback of Iran sanctions, as well as an update on FATF Proliferation Financing developments.
Monthly Update: Sudan
Released in August 2020.
Examined Hong Kong SAR/China developments, changes to CAATSA Guidance, and the UK’s autonomous human rights sanctions regime, and included a spotlight discussion on Sudan.
Monthly Update: US Access to Overseas Records
Released in July 2020.
Covered China/Hong Kong SAR developments, an update on Brexit preparations, and featured a spotlight on US access to overseas records.
Monthly Update: OFAC Reporting
Released in June 2020.
Featured a spotlight discussion on OFAC reporting, including a summary of reporting obligations and challenges for non-US persons, as well as an overview of Syria sanctions, including the CAESAR Act and the recently issued Risk Management Principles Guide. It also outlined some of the key aspects of the US Maritime Sanctions Advisory.
Monthly Update: UN DPRK Panel of Experts Report
Released in May 2020.
Covered geopolitical horizon scanning with regards to China, Russia, Venezuela, and Iran, and featured a spotlight discussion on the UN DPRK Panel of Experts report.