December 11, 2015: Financial Sanctions Alert from Central Bank of Ireland

This is the section about the latest updates:

  • IRAN
  • There have been changes made to the EU Restrictive Measures concerning Iran. Please see links below setting out the changes to the existing anti-proliferation sanctions on Iran:


    Council Regulation (EU) 2015/1861 of 18 October 2015 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran


    Council Implementing Regulation (EU) 2015/1862 of 18 October 2015 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran


  • NEW REGIME Burundi
  • Please note Council Regulation (EU) 2015/1755 of 1 October 2015 concerning concerning restrictive measures in view of the situation in Burundi . This is a new sanctions regime and comes into immediate effect.


  • Other recent Financial Sanctions news is available here.


  • The Central Bank has prepared Frequently Asked Questions (FAQs) to assist credit and financial institutions compliance with financial sanctions requirements.


  • FATF: Financing: FATF Report to G20 Leaders- actions being taken by the FATF


  • FATF: Combating the abuse of non-profit organisations


  • If implemented effectively, targeted financial sanctions are an important means to deprive terrorist and proliferation financiers of their funds, thereby protecting citizens from the threats of crime, terrorism and weapons of mass destruction. International Best Practices: Targeted Financial Sanctions Related to Terrorism and Terrorist Financing (Recommendation 6)


  • Financing of the Terrorist Organisation Islamic State in Iraq and the Levant This study identifies how funds are raised, moved and ultimately used by ISIL. This report seeks to understand how ISIL obtains and moves funds in order to (i) disrupt financial flows, (ii) deprive ISIL of its resources, and (iii) prevent ISIL from abusing relevant financial and economic sectors. Given the diversified nature of ISIL funding and operations, the report considered the broader issue of resourcing to accurately capture the complexities of this terrorist organisation.
  • Central Bank of Ireland revamps its sanctions web page

    The new page includes links to the EU Restrictive Measures and the UN's terrorism lists in multiple formats (PDF, HTML and/or XML). There are sanctions about the 3 Competent Authorities, as well as what to do if one has a sanctions match.

    Nice redesign – a lot more information than they had before.

    Links:

    Central Bank of Ireland “Introduction to Financial Sanctions”

    EU Restrictive Measures

    UNSC Terrorism list

    Derogations page (e.g. exemption from sanctions)

    Iran: Prior Notification/Authorization page

    Competent Authorities: Department of Jobs, Enterprise and Innovation, Department of Foreign Affairs and Trade

    Central Bank of Ireland FAQ

    EU Sanctions overview

    EU Restrictive Measures FAQ, Best Practices document

    UN Sanctions Committees overview

     

    April 15, 2015: Central Bank of Ireland issues reminder of sanctions obligations and updates

    Description: Description: Description: Central Bank of Ireland

    Date: 15th April 2015

    FINANCIAL SANCTIONS ALERT

    PLEASE NOTE THERE IS NO REQUIREMENT TO REPLY TO THIS EMAIL NOTIFICATION EXCEPT WHERE SPECIFIED BELOW

    Dear Subscriber,

    In order to stay up to date with Sanctions developments you should regularly visit the Central Bank web pages that relate to EU Financial Sanctions and Targeted Financial Sanctions related to Terrorism and Terrorist Financing. These pages will be updated periodically with information that will be of benefit to Credit and Financial Institutions. These pages contain information and guidance for Credit and Financial Institutions and further outline the expectations of the Central Bank.

    1. EU Financial Sanctions

    The latest EU Sanctions list is available here. It is for all institutions to ensure that they are using the most up to date information available to them. Credit and financial Institutions should be in a position to demonstrate how they ensure they are using the most up to date lists during any Central Bank visit.

    Pursuant to EU Financial Sanctions Regulations all natural and legal persons, entities and bodies are required to immediately supply any information which would facilitate compliance with such Regulations to the relevant Competent Authority. The Central Bank does not require 'nil returns' from regulated entities however the Central Bank will take it that all such regulated entities: 1. are fully in compliance with their obligations under EU Financial Sanctions Regulations, and 2. have nothing to report to the Central Bank pursuant to EU Financial Sanctions Regulations, unless and until the Central Bank is informed to the contrary.

    2. Targeted Financial Sanctions

    The latest United Nations Sanctions Committee list is available here. The Central Bank has recently updated the information on the website with some additional information on Terrorist Financing. The pages deal specifically with what Terrorist Financing is and the measures in place to try and prevent it. The page also includes information on Targeted Financial Sanctions Related to Terrorist Financing and the Obligations of Credit and Financial Institutions in the areas of monitoring, reporting and freezing action where necessary. The new pages can be viewed here.

    Credit and financial institutions:

    Institutions should ensure that their policies, procedures and processes enable them to action without delay amendments to Security Council regulations such as those included in the links above and on the Central Bank website. Institutions are expected to have a good understanding of how these Security Council regulations are addressed in their day to day operations. Institutions that utilise external electronic search providers are expected to have sufficient knowledge of the systems employed to carry out searches and be able to demonstrate how they are satisfied that they can rely on such systems.

    If you have any questions regarding this email, do not reply to it but contact the Central Bank directly:

    Financial Sanctions Unit

    Anti-Money Laundering Division

    Central Bank of Ireland

    Block D

    Iveagh Court

    Harcourt Road

    Dublin 2


    Telephone: +353 1 224 5214

    Handy-dandy guide to Irish financial sanctions

    Description: Description: Description: Description: Central Bank of Ireland

    Date: 29th January 2015

    FINANCIAL SANCTIONS ALERT

    PLEASE NOTE THERE IS NO REQUIREMENT TO REPLY TO THIS EMAIL NOTIFICATION EXCEPT WHERE SPECIFIED BELOW

    Dear Subscriber

    1. EU Financial Sanctions

    (a) Background

    The Central Bank is one of three competent authorities responsible for the administration and enforcement of EU Financial Sanctions in Ireland. EU Financial Sanctions Regulations apply to nationals of Member States and entities incorporated or constituted under the law of a Member State as well as all persons and entities doing business in the EU, including nationals of non-EU countries.

    (b) Obligations

    Pursuant to EU Financial Sanctions Regulations a person is:

    1. Required to freeze all funds and economic resources belonging to, or owned or held by a natural or legal person, body or entity listed under the relevant EU Financial Sanctions Regulation (known as listed persons or entities);

    2. Prohibited from making any funds or economic resources (within the definitions contained in the appropriate EU Financial Sanctions Regulation) available directly or indirectly to or for the benefit of listed persons or entities; and

    3. Obliged to immediately provide to the Central Bank any information which would facilitate compliance with the EU Financial Sanctions Regulations, such information to include, but is not limited to, notification of any action taken to freeze or unfreeze assets or economic resources pursuant to EU Financial Sanctions Regulations.

    Further information in relation to EU Financial Sanctions including links to the relevant lists can be found at http://www.centralbank.ie/regulation/processes/Intfs/Pages/default1.aspx

    It is the responsibility of all individuals and institutions to ensure that they are in compliance with current financial sanctions and related legislation. Details of the EU Sanctions currently in force can be accessed here.

    Note, this list is updated periodically and may not always be fully up to date and reference should also be made on a regular basis directly to the Official Journal of the European Union http://eur-lex.europa.eu/oj/direct-access.html.

    (c) Penalties

    It is a criminal offence to breach the provisions of the EU Financial Sanctions Regulations as provided for in the implementing Irish Statutory Instrument. Any person guilty of an offence under the relevant Statutory Instrument, including a failure to comply with an Instruction issued by the Central Bank, is liable on conviction to imprisonment and/or a fine.

    (d) Contact

    If you need to contact us with information that would facilitate compliance with EU Financial Sanctions Regulations or require form(s) for notification in advance or authorisation you can contact us at sanctions@centralbank.ie

    2. Targeted Financial Sanctions related to Terrorism and Terrorist Financing

    (a) Background

    Targeted financial sanctions requires regimes to comply with the United Nations Security Council resolutions (UNSCRs or resolutions) relating to the prevention and suppression of terrorism and terrorist financing.

    Under the Criminal Justice (Terrorist Offences) Act 2005 it is an offence to finance terrorism within or outside the State. Under the Criminal Justice Act 2010 a designated person must have systems and controls in place to prevent the financing of terrorism.

    (b) Obligations of credit and financial institutions

    To ensure that a designated person is not facilitating the financing of terrorism it should monitor both the EU and UN Sanctions lists relating to terrorism. Please note the lists are regularly updated and must be checked to ensure that the list is the latest one available.

    The following lists should be monitored to ensure compliance with relevant domestic and EU legislation.

    EU Link to the consolidated list of persons, groups and entities subject to EU financial sanctions http://eeas.europa.eu/cfsp/sanctions/consol-list/index_en.htm

    UN Link to the consolidated United Nations Security Council Sanctions List- http://www.un.org/sc/committees/consolidated_list.shtml.

    The Consolidated list maintained on this website was last updated on 2 January 2015, and supersedes all previous versions

    Information on targeted financial sanctions can be found at http://www.un.org/sc/committees/index.shtml

    (c) What to do if a “hit” occurs

    Should a “hit” be made with a person or entity contained in the EU or UN terrorist lists, designated persons should report the hit immediately to the Garda Síochána (and Revenue) and await further direction. A failure to report a hit may be an offence under the CJA 2010 and the Criminal Justice Act 2011.

    (d) Penalties

    It is a criminal offence to breach relevant EU Financial Sanctions Regulations as provided for in the implementing Irish Statutory Instrument. It may also, or in the alternative, amount to a breach of the Criminal Justice (Terrorist Offences) Act 2005, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and the Criminal Justice Act 2011.

    (e) Contact

    If you need to contact us with information that would facilitate compliance with targeted Financial Sanctions relating to Terrorist Financing you can contact us at sanctions@centralbank.ie

    If you have any questions regarding this email, do not reply to it but contact the Central Bank directly:

    Financial Sanctions Unit

    Anti-Money Laundering Division

    Central Bank of Ireland

    Block D

    Iveagh Court

    Harcourt Road

    Dublin 2

    Telephone: +353 1 224 5214

    “***********************************************************************************************************************************************************************************************”

    This e-mail is from the Central Bank of Ireland. The e-mail and any attachments transmitted with it are confidential and privileged and intended solely for the use of the individual or organization to whom they are addressed. Any unauthorised dissemination, distribution or copying, direct or indirect, of this e-mail and any attachments is strictly prohibited. If you have received this e-mail in error, please notify the sender and delete the material from your system.

    “***********************************************************************************************************************************************************************************************”

    Tagann an ríomhphost seo ó Bhanc Ceannais na hÉireann. Tá an ríomhphost, agus aon iatán a ghabhann leis, faoi rún agus faoi phribhléid agus ceaptha d’aontoisc le haghaidh úsáide an té nó na heagraíochta chun a ndíreofar iad. Tá dianchosc ar chraobhscaoileadh, ar dháileadh nó ar chóipeáil neamhúdaraithe ar bith, díreach nó indíreach, an ríomhphoist seo nó aon iatán a ghabhann leis. Má tá an ríomhphost seo faighte agat trí dhearmad, cuir an seoltóir ar an eolas agus scrios an t-ábhar ó do chóras le do thoil.

    “***********************************************************************************************************************************************************************************************”

     

    Handy-dandy guide to Irish financial sanctions

    Description: Description: Description: Description: Central Bank of Ireland

    Date: 29th January 2015

    FINANCIAL SANCTIONS ALERT

    PLEASE NOTE THERE IS NO REQUIREMENT TO REPLY TO THIS EMAIL NOTIFICATION EXCEPT WHERE SPECIFIED BELOW



    Dear Subscriber


    1. EU Financial Sanctions

    (a) Background

    The Central Bank is one of three competent authorities responsible for the administration and enforcement of EU Financial Sanctions in Ireland. EU Financial Sanctions Regulations apply to nationals of Member States and entities incorporated or constituted under the law of a Member State as well as all persons and entities doing business in the EU, including nationals of non-EU countries.


    (b) Obligations

    Pursuant to EU Financial Sanctions Regulations a person is:

    1. Required to freeze all funds and economic resources belonging to, or owned or held by a natural or legal person, body or entity listed under the relevant EU Financial Sanctions Regulation (known as listed persons or entities);

    2. Prohibited from making any funds or economic resources (within the definitions contained in the appropriate EU Financial Sanctions Regulation) available directly or indirectly to or for the benefit of listed persons or entities; and

    3. Obliged to immediately provide to the Central Bank any information which would facilitate compliance with the EU Financial Sanctions Regulations, such information to include, but is not limited to, notification of any action taken to freeze or unfreeze assets or economic resources pursuant to EU Financial Sanctions Regulations.


    Further information in relation to EU Financial Sanctions including links to the relevant lists can be found at http://www.centralbank.ie/regulation/processes/Intfs/Pages/default1.aspx

    It is the responsibility of all individuals and institutions to ensure that they are in compliance with current financial sanctions and related legislation. Details of the EU Sanctions currently in force can be accessed here.

    Note, this list is updated periodically and may not always be fully up to date and reference should also be made on a regular basis directly to the Official Journal of the European Union http://eur-lex.europa.eu/oj/direct-access.html.

    (c) Penalties

    It is a criminal offence to breach the provisions of the EU Financial Sanctions Regulations as provided for in the implementing Irish Statutory Instrument. Any person guilty of an offence under the relevant Statutory Instrument, including a failure to comply with an Instruction issued by the Central Bank, is liable on conviction to imprisonment and/or a fine.

    (d) Contact

    If you need to contact us with information that would facilitate compliance with EU Financial Sanctions Regulations or require form(s) for notification in advance or authorisation you can contact us at sanctions@centralbank.ie

    2. Targeted Financial Sanctions related to Terrorism and Terrorist Financing

    (a) Background

    Targeted financial sanctions requires regimes to comply with the United Nations Security Council resolutions (UNSCRs or resolutions) relating to the prevention and suppression of terrorism and terrorist financing.

    Under the Criminal Justice (Terrorist Offences) Act 2005 it is an offence to finance terrorism within or outside the State. Under the Criminal Justice Act 2010 a designated person must have systems and controls in place to prevent the financing of terrorism.

    (b) Obligations of credit and financial institutions

    To ensure that a designated person is not facilitating the financing of terrorism it should monitor both the EU and UN Sanctions lists relating to terrorism. Please note the lists are regularly updated and must be checked to ensure that the list is the latest one available.

    The following lists should be monitored to ensure compliance with relevant domestic and EU legislation.

    EU Link to the consolidated list of persons, groups and entities subject to EU financial sanctions http://eeas.europa.eu/cfsp/sanctions/consol-list/index_en.htm

    UN Link to the consolidated United Nations Security Council Sanctions List- http://www.un.org/sc/committees/consolidated_list.shtml.

    The Consolidated list maintained on this website was last updated on 2 January 2015, and supersedes all previous versions

    Information on targeted financial sanctions can be found at http://www.un.org/sc/committees/index.shtml

    (c) What to do if a “hit” occurs

    Should a “hit” be made with a person or entity contained in the EU or UN terrorist lists, designated persons should report the hit immediately to the Garda Síochána (and Revenue) and await further direction. A failure to report a hit may be an offence under the CJA 2010 and the Criminal Justice Act 2011.

    (d) Penalties

    It is a criminal offence to breach relevant EU Financial Sanctions Regulations as provided for in the implementing Irish Statutory Instrument. It may also, or in the alternative, amount to a breach of the Criminal Justice (Terrorist Offences) Act 2005, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and the Criminal Justice Act 2011.

    (e) Contact

    If you need to contact us with information that would facilitate compliance with targeted Financial Sanctions relating to Terrorist Financing you can contact us at sanctions@centralbank.ie

    If you have any questions regarding this email, do not reply to it but contact the Central Bank directly:

    Financial Sanctions Unit

    Anti-Money Laundering Division

    Central Bank of Ireland

    Block D

    Iveagh Court

    Harcourt Road

    Dublin 2

    Telephone: +353 1 224 5214

    “***********************************************************************************************************************************************************************************************”

    This e-mail is from the Central Bank of Ireland. The e-mail and any attachments transmitted with it are confidential and privileged and intended solely for the use of the individual or organization to whom they are addressed. Any unauthorised dissemination, distribution or copying, direct or indirect, of this e-mail and any attachments is strictly prohibited. If you have received this e-mail in error, please notify the sender and delete the material from your system.

    “***********************************************************************************************************************************************************************************************”

    Tagann an ríomhphost seo ó Bhanc Ceannais na hÉireann. Tá an ríomhphost, agus aon iatán a ghabhann leis, faoi rún agus faoi phribhléid agus ceaptha d’aontoisc le haghaidh úsáide an té nó na heagraíochta chun a ndíreofar iad. Tá dianchosc ar chraobhscaoileadh, ar dháileadh nó ar chóipeáil neamhúdaraithe ar bith, díreach nó indíreach, an ríomhphoist seo nó aon iatán a ghabhann leis. Má tá an ríomhphost seo faighte agat trí dhearmad, cuir an seoltóir ar an eolas agus scrios an t-ábhar ó do chóras le do thoil.

    “***********************************************************************************************************************************************************************************************”

    Ireland: I have no responsibilities here whatsoever

    (movie reference is to “A Few Good Men” – awesome flick)

    From the Central Bank of Ireland:

    Central Bank of Ireland

    Date: 7th July 2014

    Re: EU Financial Sanctions in pursuit of the objectives of the Common Foreign and Security Policy (CFSP) and related Irish Statutory Instruments (“EU Financial Sanctions”)

    Dear Subscriber

    The Central Bank of Ireland (the “Central Bank”) is the Competent Authority responsible for the administration and enforcement of EU Financial Sanctions in Ireland.

    EU Financial Sanctions Regulations apply to nationals of Member States and entities incorporated or constituted under the law of a Member State as well as all persons and entities doing business in the EU, including nationals of non-EU countries. A list of all EU restrictive measures, including EU Financial Sanctions Regulations in force is available here. Note, this list is updated periodically and may not always be completely up to date. It is the responsibility of all individuals and institutions to ensure that they are in compliance with current financial sanctions and related legislation.

    You can find additional information in relation to the operation of EU Financial Sanctions in Ireland and the role of the Central Bank on the International Financial Sanctions pages of our website athttp://www.centralbank.ie/regulation/processes/Intfs/Pages/default1.aspx

    Contravention of EU Financial Sanctions is an offence and it is the responsibility of all individuals and institutions to ensure that they are in compliance with current sanctions and related legislation. If you suspect or are aware of a breach under EU Financial Sanctions legislation you should notify the Central Bank. You may also wish to report it to the Garda Bureau of Fraud Investigation, 'C' Branch, Harcourt Street, Dublin 2.

    To contact the Central Bank directly please refer to the below details:

    Financial Sanctions Unit,

    Anti-Money Laundering Division,

    Central Bank of Ireland,

    Block D,

    Iveagh Court,

    Harcourt Road,

    Dublin 2.

    Email: sanctions@centralbank.ie

    Website: http://www.centralbank.ie/regulation/processes/Intfs/Pages/default1.aspx

    “***********************************************************************************************************************************************************************************************”

    This e-mail is from the Central Bank of Ireland. The e-mail and any attachments transmitted with it are confidential and privileged and intended solely for the use of the individual or organization to whom they are addressed. Any unauthorised dissemination, distribution or copying, direct or indirect, of this e-mail and any attachments is strictly prohibited. If you have received this e-mail in error, please notify the sender and delete the material from your system.

    “***********************************************************************************************************************************************************************************************”

    Tagann an ríomhphost seo ó Bhanc Ceannais na hÉireann. Tá an ríomhphost, agus aon iatán a ghabhann leis, faoi rún agus faoi phribhléid agus ceaptha d’aontoisc le haghaidh úsáide an té nó na heagraíochta chun a ndíreofar iad. Tá dianchosc ar chraobhscaoileadh, ar dháileadh nó ar chóipeáil neamhúdaraithe ar bith, díreach nó indíreach, an ríomhphoist seo nó aon iatán a ghabhann leis. Má tá an ríomhphost seo faighte agat trí dhearmad, cuir an seoltóir ar an eolas agus scrios an t-ábhar ó do chóras le do thoil.

    “***********************************************************************************************************************************************************************************************”

    We’re expanding in Europe!

    Hi, readers –

    Two changes to Mr. Watchlist on tap today. The first is that we've added the Swedish sanctions pages to the Regulatory Links page. Secondly, we discovered that the Central Bank of Ireland has its own email alerts for regulatory changes, so you'll get their updates as soon as I do.

    If there are countries you'd like me to try to keep better track of, please let me know. A lot of countries don't have email notifications or RSS feeds, and it's hard to navigate sites that don't supply English navigation (well, it is for Mr. Watchlist).