Sanctions vol 2

OFAC (The Office of Foreign Assets Control) is

• the main Financial Intelligence Unit in USA

• the main body that conducts SAR procedures in USA

• is one of the main bodies

  that administers and enforces economic and trade sanctions based on US foreign policy and national security

  goals.

• the main body that administers foreign politics in USA

Which of the mentioned below evasion techniques connected to payments is based on an intentional removal or modification of information from the bank record message (i.e. SWIFT), either by the customer or by an FI’s staff?

• structuring

• blocking the assets

• stripping

• concealment

The New York Department of Financial Services is

• a body that regulates all licensed financial institutions which

  operate in New York.

• is an association of 12 global banks which aims to develop frameworks and guidance for the management of financial crime risks.

• is the main financial authority in USA.

• organisation founded in 1989 on the initiative of the G7 to develop policies to combat money laundering.

Financial Crime Guide that

mentions mainly topics related to compliance with sanctions and asset freezes was published by

• The Financial Action Task Force

• The New York Department of Financial Services

• The Office of Foreign Assets Control ("OFAC")

• The Financial Conduct Authority’s (FCA).

What are the two types of sanction evasion?

• internal and external

• global and individual

• organised and disorganised

transaction is performed by a bank in country A, for the benefit of a bank in country B, but the transaction is

sent through an offshore bank - that technic is called:

• U-turn payments

• striping

• structuring

Document falsification is a method used in which sanction evasion technic

• structuring

• striping

• concealment

which of mentioned below sanction evasion technique are connected to beneficial ownership? (3 correct answers)

• Consolidation of goods

• Complex corporate structures

• Dilution of sanctioned ownership

• Using a proxy or a nominee

Can the Financial Institution tell the sanctioned person that his/her assets have been

blocked/frozen?

• yes

• no