The expected reemergence of Iran on global markets will likely pose the toughest challenge for sanctions compliance officers in the coming year, according to Alexandre Lamy, an attorney with Baker & McKenzie's International Trade Practice Group.
Although the grandson of a former head of the Communist Party USA, Bill Browder isn't exactly beloved by Russian officials, even those professing nostalgia for the Soviet Union's supposedly golden days.
At its highest levels, Russian corruption over the past 20 years has been disguised by networks of shell companies and facilitated by foreign banks willing to turn a blind eye to state embezzlement, according to Karen Dawisha, a political science professor at Ohio-based Miami University.
This time last December, one might reasonably have expected that 2014 would be a year of modest changes for the anti-money laundering and sanctions compliance sector. Then came JPMorgan Chase, BNP Paribas and a convoy of Russian tanks to quash that notion.
For the fourth time this year, U.S. officials blacklisted an Iranian national using a Caribbean passport while purportedly helping Iran circumvent sanctions.
U.S. lawmakers may soon have enough support to pass a veto-proof measure that would clear the way for sanctions against foreign banks that deal with blacklisted Iranian entities in foreign currencies.
American elections, EU court decisions and a potential wind-down of negotiations with Iran are complicating efforts by the United States and Europe to maintain uniformity in sanctions enforcement, say analysts.
European companies may be lining up at the gate to do business with Iran in the event of a sanctions rollback but don't expect the continent's banks to go rushing in anytime soon.
The expansion of Western sanctions targeting Russia will require banks to closely vet additional types of credit and transactions tied to financial, energy and defense firms, according to attorneys.
For the first time, U.S. officials have blacklisted a foreign financial institution using a July 2012 executive order that prohibits significant transactions with the Central Bank of Iran.
Even with limited sanctions relief from the United States, foreign banks have been reluctant to process transactions for Iran under the terms of a newly-extended multilateral accord, an American official said Tuesday.
U.S. officials are preparing to press their EU counterparts on stronger Russia sanctions ahead of a European Council meeting next week, State Department representatives told the Senate Foreign Relations Committee Wednesday.
Threatened U.S. sanctions against large swathes of Russian businesses would likely target defense and financial firms ahead of energy companies if imposed, according to experts.
The first line of the Ukrainian national anthem could well apply to the battered nation's banks these days: "Ukraine is not dead yet."
U.S. officials have no plans to negotiate Russia's compliance with an anti-tax evasion law that takes effect this summer and could impose stiff monetary penalties on nonparticipating financial institutions.
U.S. sanctions against 17 Russian individuals and companies, including three banks and the head of one of the nation's largest energy companies, will raise more questions than answers for compliance officers.
Although sanctions on Russian nationals and companies might seem fairly innocuous at first blush, compliance departments at European banks are finding the task of identifying designees unusually difficult, say legal experts.
The House Committee on Foreign Affairs advanced amended legislation Tuesday that would require U.S. officials to report on banks linked to the embezzlement of Ukrainian assets.
In announcing sanctions against Russian politicians and one bank Thursday, U.S. officials made clear that American financial institutions should prepare for more, and soon.
Diplomatic tension over Ukraine has raised doubts that the United States will attend an upcoming Moscow plenary of the world's largest anti-money laundering task force, say current and former officials.