Sanctions Intelligence Update – FARC: Peace Accord and The Enduring Illicit Finance Threat

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The November 2016 peace accord between the Colombian Government and the Revolutionary Armed Forces of Colombia (FARC) includes a 180-day FARC disarmament deadline on May 29, 2017. By most accounts, the FARC has been slow to comply with the demobilization process, raising questions about the future of the peace agreement, and the sanctions relief that could accompany political normalization with the FARC. Colombian President Santos, who met with President Trump on May 18, 2017 in Washington, DC, has already publicly indicated that the deadline for full FARC disarmament may need to be extended. Although the UK revoked the FARC’s terror-related designation last fall, the group remains sanctioned by the US as both a terrorist and narcotics trafficking group. Recent reports of breakaway FARC commanders and military factions — many with extensive histories in drug trafficking — suggest a continuing threat of FARC-related criminal activity. The FARC has also yet to disclose a significant portion of their illicit assets for use as reparations, as required by the accord.

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Sanctions Intelligence Update – Burma: Examining Risk Post Sanctions Relief

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In October 2016, the United States substantially lifted sanctions on Burma as an economic incentive to continue positive political developments within Burma. The lifting of sanctions is intended to encourage an increase in international commercial activity with, and foreign investment in Burma. Corporates and financial institutions with exposure to Burma should consider the illicit finance and money laundering risks that underpinned the sanctions measures, many of which persist regardless of the political dynamics.

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Sanctions Intelligence Update – Yemen: Assessing Risk to the Financial System

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The Houthi group and forces aligned with Yemen’s ex-President Ali Abdullah Saleh have exercised control over several Yemeni financial institutions, including the Central Bank, since seizing Yemen’s capital city of Sanaa in late 2014. During the same period, Al Qaida’s local affiliate “AQAP” also expanded its presence in Yemen, increasing the group’s exploitation of the Yemeni financial system to raise and move funds.

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Use of Social Media by Terrorist Fundraisers & Financiers

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Financiers and fundraisers for al-Qaida and Islamic State (ISIS) are active users of popular social media platforms, such as Facebook, Twitter, YouTube and Instagram, in some cases even after being placed on a United Nations or US government sanctions list. Terrorist financiers and fundraisers have utilized social media to attract and direct funding to procure weapons, pay salaries, strengthen infrastructure and operate civil and social services…

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Crimea: Sanctions Risk Considerations

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On December 22, 2015, the US Treasury Department designated three Russian banks and one Crimea-based bank for operating in Crimea. The three designated Russian banks are Genbank, Krasnodar Regional Investment Bank, and Bank Verkhnevolzhsky. The Crimea-based bank is Sevastopolsky Morskoy Bank.

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