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Uncertain times ahead for sanctions
Journal of Financial Compliance,
2
(1),
60-65
(2018)
Abstract
In the first half of 2018 updates to the sanctions landscape have made headline news. This paper will first focus on the considerable impact of the Trump Administration’s decision to withdraw from the nuclear agreement with Iran. It will then turn to the current uncertainty regarding a possible sanctions relief on North Korea before examining the impact of the Countering America’s Adversaries Through Sanctions Act (CAATSA) with a particular focus on Russia. Finally, the paper discusses the amendments to the Cuba sanctions policy which are the result of President Trump’s commitment to reverse the Obama Administration’s policy of easing sanctions against Cuba. As a result of the uncertainty created by these headlines there has been a noticeable slowdown in deals involving riskier sectors or entities associated with these countries. This paper provides an overview of how uncertainty is affecting the sanctions landscape.
Keywords: sanctions; Iran; Joint Comprehensive Plan of Action (JCPOA); North Korea; Cuba; Russia
The full article is available to subscribers to the journal.
Author's Biography
Daniel L. Tannebaum is a principal in PwC’s Financial Crimes Unit and the Leader of the Global Financial Services Sanctions Practice. Daniel provides anti-money laundering (AML) and sanctions regulatory crisis management support to global financial institutions including banks, broker dealers and money services businesses. He also provides strategic AML and sanctions compliance programme support during both programme creation and remediation. Dan has supported the Global AML and Sanctions Remediation for several global systemically important financial institutions (G-SIFIs) under investigation or subject to enforcement actions. He has lead the design of target operating models, programme governance frameworks, policies and procedures, and communication strategies for over a dozen global financial institutions. Previously, Dan served as the Head of Compliance for the Americas and Global Sanctions Champion at Travelex. In this capacity he directed a staff of over 30 compliance professionals in the USA, Canada and Brazil. Before joining Travelex, Dan was the Office of Foreign Assets Control Compliance Coordinator for the Federal Reserve Bank of New York, where he advised on Office of Foreign Assets Control (OFAC) issues. Dan began his career in compliance when he served as a compliance officer with the Office of Foreign Assets Control, US Department of the Treasury. Dan received the FBI Director’s Certificate for Exceptional Service in the Public Interest in May 2007. He was an instructor at the Department of Homeland Security’s Federal Law Enforcement Training Center course on International Banking and Money Laundering and has trained Federal Reserve national supervisory examiners and Federal Deposit Insurance Corporation examiners on OFAC regulations and policies. Dan is a regular guest on Bloomberg TV and speaks at industry forums and governments events globally on the topic of anti-money laundering and sanctions compliance.
