Will be exploring the world of risk management and its nexus across sanctions, money laundering and fraud, among other risk areas. The newsletter shall cover the latest regulations, enforcement actions and market trends across EMEA, APAC and the Americas.

EMEA

Enforcement

Bet365 will pay GBP 582,120 for social responsibility and AML failures, including over-reliance on customers’ annual self-verification of KYC information, failure to conduct sanctions checks prior to the initial deposit, and lack of clear distinction between “at risk” and “"not at risk” customer profiling.

Enforcement

On 10 April 2024, the European Court of Justice ruled out that Mikhail Fridman and Petr Aven should not have been included on the EU restrictive measures list between February 2022 and March 2023. Noteworthy, the individuals are currently sanctioned - the appeal for their sanctioned status March 2023 is still under consideration.

Regulation

The OFSI published a brief on how businesses with maritime nexus can stay compliant with financial sanctions. Great supplement to the Oil Price Cap Guidance released in March 2024.

APAC

Enforcement

On 9 April 2024, the Federal Court of Australia ruled out that Australia’s Autonomous Sanctions Act applies to the coal produced by Tiger Realm Coal’s (ASX:TIG) indirect subsidiaries in Russia.

Regulation

Japan’s Financial Services Agency published revised FAQ on the AML/CTF guidelines. First published in 2018, the FAQs are meant to help financial institutions navigate the country’s regulations with proactive implementation of the risk-based approach.

Market

Taiwan’s Financial Supervisory Commission brought together financial institutions, telcoms and tech firms to discuss how technology can help combat fraud. It was determined that natural language processing technology and network analysis can help verify the customer’s identity and identity fraud patterns.

Americas

Regulation

The US and UK imposed new restrictions on Russian aluminum, copper and nickel, prohibiting delivery of new supplies from Russia to the London Metal Exchange (LME) and the Chicago Mercantile Exchange (CME). Russian metal accounted for 36% of nickel, 62% of copper and 91% of the aluminum on the LME, as of 30 March 2024.