Compliance and ‘Commodities of Concern’: Identifying Export Control Evasion
Though it’s often conflated with sanctions enforcement, fighting export control evasion is a topic worthy of consideration on its own.
Apply Customer Due Diligence measures instead of transaction monitoring to combat export control evasion
Find red flags for suspicious activity, including comparing transaction volumes before and after sanctions
Cooperate across borders with branches of your own financial institutions to help identify export control evasion
Lynn Li, CAMS-Audit, AML Director – Greater China, ACAMS
Ajay Budhrani, CAMS, Head of Compliance Advisory, for Consumer, Private and Business Banking, Asia, Standard Chartered Bank
Mike Kung, Executive Director and Senior Counsel, Goldman Sachs