Money laundering reporting officers and compliance officers at financial institutions who number amongst their clients Serbian nationals, Serbian companies, and Serbian PEPs should assign a compliance member to monitor the unfolding developments in the Serbian situation, and especially the tenor, tone and substance of US diplomatic statements on the subject. They may provide advance warning of imminent sanctions.

The imposition of OFAC sanctions upon some of the more radical elements of the Serbian government, especially those who inflamed extremist passions, is a real possibility. The United States has often resorted to the OFAC blacklist to enforce national foreign policy goals, and one should not expect the present administration to retreat from that approach.

  Since it is common knowledge that many wealthy members of the Serbian government maintain accounts outside the country, prudence dictates that such individuals who bank with your institution be re-examined at this time for risk purposes. In the event that any are listed as SDNs, OFAC press releases must be closely scrutinised to learn all possible aliases, company affiliations, and an immediate comparison of the client list against the World-Check data-file be instituted, to cull out any sanctioned individuals and companies forthwith.

Judging by the massive amount of diplomatic support given to the new Kosovo government by the United States, it might be appropriate to identify any and all Serbian PEPs with whom you have account reslationships, and to access their current risk status. So do not get caught unawares when sanctions notices appear; check out your bank's exposure immediately, as it may save you a lot of long work-nights later on.