Identifying and interdicting sanctions risk in global transhipment and intermediary points.

Multi-layered complexities in a set of OFAC exposures call for enhanced controls.
  • 21 Junio 2017

A series of actions by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) throughout 2016 and into 2017, including multiple enforcement actions and designations, highlighted the sanctions risk posed by transshipment and intermediary points — geographic and financial hubs for goods and payments ultimately destined to sanctioned jurisdictions.

Patterns in regulatory focus are typically established through years of guidance, enforcement actions and consistent public messaging. It is notable that many of OFAC’s 2016 actions highlighted a common theme: the shipment of goods and processing of payments to sanctioned jurisdictions through third-party countries that are not sanctioned. Some of these enforcement actions dealing with transshipment and intermediary risk were levied against financial institutions, which, regulators argue, “should have known” that they were facilitating prohibited activity.

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