Alexey's Newsletter: No. 3

UFLPA - Revised 2024 Strategy - New High Priority Sectors

On 9 July 2024, the Department of Homeland Security released the revised Uighur Forced Labor Protection Act (UFLPA) strategy, building on the lessons learnt during the past two years. Aluminum, polyvinyl chloride and seafood have been identified as high-priority sectors for the first time (p.17). Businesses in these industries must step up their supply chain screening efforts to prevent disruption of their business on the US border. Other previously designated high-priority sectors include apparel, cotton, silica-based products as well as tomatoes.

EU - 14th Sanctions Package

On 24 June 2024, the EU adopted its 14th Russia sanctions package, which includes restrictive measures on 116 individuals and entities, as well as various other measures targeting Russia’s energy, trade and finance sectors. Noteworthy, the EU persons will be required to take their “best efforts” to ensure their foreign subsidiaries do not partake in any activities contrary to the sanctions’ intended outcomes. The EU Council advised that the firms’ due diligence mechanisms must be capable of identifying red flags across the entire risk spectrum.

FinCEN - AML/CTF Programs at Financial Institutions

On 28 June 2024, FinCEN issued a Proposed Rule to strengthen AML/CTF programs at financial institutions. Considering “serious law enforcement and national security issues”, this proposal would amend existing AML/CTF programs, “explicitly” requiring target entities to tailor their regulatory and supervisory regime in a manner consistent with the institution’s risk profile. Noteworthy, this rule will require financial institutions to incorporate government’s AML/CTF priorities.

US Department of Commerce - Entity List

On 2 July 2024, the Bureau of Industry and Security expanded the Entity List by adding entities across multiple jurisdictions (China, Turkiye, UAE, Kazakhstan, etc.). The purpose is to prevent entities that threaten US national security from accessing items subject to the Export Administration Regulations.

Philippines - Guidance on Beneficial Ownership Due Diligence

Central Bank of Philippines (BSP) issued a Guidance on beneficial ownership due diligence measures for financial institutions. The document emphasizes the importance of risk-based approach to beneficial ownership identification and verification, using the information provided by customers against independent and reliable sources.