Why non-US entities keep falling foul of the US Sanctions & AML regime

The current revelations and allegations surrounding Nordic banks from otherwise highly reputed, transparent jurisdictions such as Sweden, Denmark, Norway and Finland reflect a typical European reluctance to accept Extra-Territoriality.

The US dollar is the single most important currency in the world with comfortably the largest share in terms of currency transactions, reserve currency and global investment presence. This has given the US unrivalled ability to leverage its national and foreign policy objectives.

Speech in Copenhagen at the InsightFinance AML Conference 8-9 October 2019 There is currently a clear lack of understanding of the true cross-border threat of US sanctions – which implicitly include AML and CTF violations.

In 2012 the US Congress passed the Magnitsky Act, as a means of US legislative protection against human rights abuses. This was followed up by a more international, cross-border version of the initial Act, called the Global Magnitsky Act, in 2017.

The real truths of former PM May and former Chancellor Hammond’s failed Withdrawal Treaty emerging – over the incomprehensible approach to the European Investment Bank included in the Withdrawal Treaty, which was rejected three times by the UK Parliament.

The US President’s Annual Address to the UN Assembly, which takes place in September, should be followed closely by those looking at the wider Sanctions, strategic, domestic and foreign policy goals of the US Government.

As the entire US sanctions regime has integral money laundering offence types, when extra-territorial actions involving foreign firms are investigated by US agencies, it is highly likely that sanctions-related offences – which typically carry the highest penalties – are being scrutinised.

Iain Stewart to deliver opening remarks at The Launch of The Global Financial Centres Index 26 – Guildhall London

Interview with Iain Stewart for the InsightFinance Money Laundering Conference in Copenhagen 8-9 October 2019.