Sanctions

When ransomeware strikes: Navigating risks and regulatory responses

Ransomware attacks are affecting millions of organisations worldwide. What is the correct response when someone breaks into your organisation’s IT system, encrypts critically important data and demands a ransomware payment in exchange for an encryption key? Besides the obvious information security and business continuity concerns, there are other important aspects to consider, such as the…

Sanctions: Trends and challenges in a tumultuous year

On 25 February 2023, the EU marked the one-year anniversary of Russia’s full-scale invasion of Ukraine by announcing its tenth package of sanctions against Russia. The new package added some 121 individuals and entities to the EU’s sanctions list, bringing the total under either an asset freeze or travel ban to 1,473 individuals and 205…

Russian parliamentary elections – a not so glorious victory

United Russia’s victory in the Russian parliamentary election in September 2021 is unlikely to mark a departure from the strained relationship of EU and US with Russia and to improve the prospects for doing international business in the country. Only the more robust investors are willing to accept the risks linked to operating in the…

The future of US sanctions on Iran

One of the top foreign policy priorities for the Biden administration is to strike a new nuclear deal with Iran. The administration got one step closer to reaching this goal at the beginning of April when indirect talks began between the two parties in Vienna to negotiate a return to the Obama-era deal (JCPOA, see…

The Rocky Road Ahead for US-Russia Relations

Relations between the US and Russia are widely expected to continue their downward trajectory when President Biden enters office on 20th January. Biden arrives in office in very different circumstances from previous incumbents. In most recent cases, US presidents have started their terms by seeking better relations with Russia. This time, however, there are no illusions…

Take-Aways – ACAMS Conference – Berlin 2019

Berlin Risk joined ACAMS 15th Annual Anti-Financial Crime Conference as an exhibitor, sponsor and speaker at the Berlin conference in June 2019. Berlin Risk’s Managing Director, Jennifer Hanley-Giersch, took part as a panelist focusing on the management of high-risk customers. She discussed adequate approaches to customer risk rating and what levels of investigations are necessary to also address reputational risk. With high-risk clients it is not sufficient to simply identify the UBO. “It is important to have an in-depth understanding of who the customer is, the countries of operations, wider business interest and political associations,” Jennifer said.

Scenarios for Regime Change in Venezuela

The domestic power-struggle in Venezuela between the acting regime leader, Nicolás Maduro, and opposition leader, Juan Guaidó, claiming presidency and calling for a free elections, is exacerbated by the geopolitical rivalry between Russia, supporting Maduro, and the US, supporting Guaidó, over the country’s fate.

EU Methodology for Identifying High-Risk Third Countries

The 5th EU Anti-Money Laundering Directive, in force as of 11 July 2018, includes amendments to the 4th AML Directive, among them improvements in the assessment of high-risk third countries. Moreover, the EU Commission has recently published a relevant methodology for identifying such countries with strategic deficiencies in combating money laundering and terrorist financing.

Know your customer: Enhanced requirements

KYC/CDD requirements have been the focus of regulatory revision in 2016, leading to changes in understanding, approaches and tools needed to meet these requirements.