With the announcement that Iran's national oil company will now issue $1bn worth of bonds to develop the South Pars Oil Field, the question presents itself: why will European banks risk US and/or UN sanctions by handling these instruments ? The bonds, which will return 5.5 to 8%, will reportedly be issued in Euros, and in up to €100,000 denominations, are being marketed by a government-owned [and sanctioned] Iranian financial institution. Apparently Iran's Parliament has authorised the issuance of up to €5bn.

The extensive damage caused by Cyclone Tomas, which hit the Republic of the Fiji islands this week, has resulted in a disruption in communications, and in the delivery of utilities and government services. A 3-day state of natural emergency has been declared, and there are unverified reports of loss of life. A number of residences have been destroyed by the category four storm. A call for international aid has been reported, which is a clear sign that the cyclone has inflicted serious damage upon the island nation.

The Office of Foreign Assets Control [OFAC] has added* a large number of Colombian nationals and entities to the list of Specially Designated Narcotics Trafficking Kingpins (SDNTK). If you have a client base that includes Colombian customers, you would be well advised to immediately download, and run, the World-Check Data-File against your list of clients, to ensure that you are not now unwittingly violating OFAC regulations.

The Office of Foreign Assets Control [OFAC] has effectively loosened the terms of payment for US agricultural products destined for the Republic of Cuba. Farms sales of US goods are exempt from the embargo [Cuban Assets Control Regulations] administered by OFAC. A Final Rule*, published this week in the Federal Register, dealing with "Payment of Cash in Advance," is summarised here for the benefit of compliance officers at financial institutions whose clients export agricultural products to Cuba. 

it would appear that bulk cash smuggling into Mexico from Southern California is on the increase in 2010. Immigration & Customs Enforcement [ICE] has reported that they apprehended nineteen suspects in the act just since October 2009. Since many narcotics trafficking organisations find other methods of moving drug profits into the border states, to reduce the risk of seizure whilst in transit from northern areas of the US, expect that front companies will take delivery of large sums, via cheques or wire transfers, and then withdraw the cash for the onward final leg into Mexico. 

The unrest in a Nigeria still unable to resolve its problems manifested itself in a major demonstration by elements opposed to the existing government, who demanded that the cabinet be sacked. The vice president, attempting to fill the shoes of the ailing and invisible president, has himself made changes in senior officers, but the government appears to have lost the peoples' confidence. Add to that the ethnic and religious violence that continues to take place in the area where the two principal religions intersect, and you have a recipe for disaster. Runaway corruption, at the highest levels, continues unabated, and prudent risk managers, seeking to protect their financial institutions, really have no choice but to increase country risk for Nigeria.

The Office of Foreign Assets Control [OFAC] has published its updated "List of Authorised Providers of Air, Travel and Remittance Forwarding Services to Cuba." If your client base includes any of these categories, you should review it at this time,  

Prominent Florida forensic accountant Lewis Freeman, a major figure in many of the important Florida fraud cases of the past fifteen years, now himself indicted for fraud and embezzlement, this week entered a plea of guilty to a count of conspiracy to commit mail fraud. Freeman, himself an attorney, was often appointed by members of the judiciary to act as a receiver, and authorised to recover funds taken by fraudsters from local investors. He was charged with embezzling from those very accounts. 

Treasury has announced that the latest three Civil Penalty and Enforcement Information press releases, for February and March 2010, have been published* to the OFAC website. The magnitude of the civil fines, some of which have been accompanied by criminal penalties,** should indicate to you the zero tolerance approach that US law enforcement takes with violators of the existing sanctions against Iran. if you have any bank clients who, directly or indirectly, may be dealing with Iran, whether through Dubai or otherwise, you need to look at this. 

Can a government official "successfully" take a bribe without receiving money or a gift, and thereby minimise his chances of being exposed to an FCPA violation, because there's no paper trail ?  He certainly can, at the place where the Foreign Corrupt Practices Act (and the proposed UK Bribery Bill) meets trade-based money laundering. Professor John Zadanowicz, from Florida international University, who first scientifically proved the existence of widespread trade-based money laundering two decades ago, explains it all.