DIFFERENT ANGLE by Kenneth Rijock
In a blunt statement directed to that segment of the global financial community that facilitates international trade, a senior US official warned this week that banks that assist Iran in its acquisition of dual-use (controlled) technology face the possibility of "Legal Risks." Whilst we do not know precisely what such a term means, as it was not further clarified, the risk of regulatory sanctions, or even criminal indictment for providing financial support for terrorism are the probable intent of that statement.
Perhaps we need to take this at face value, given the take-no-prisoners position that the present US government has presented involving violations by US banks and NBFIs regarding Iran. it is humbly suggested that compliance initiate an internal investigation to ensure that there is no trade financing of dual-use technology being shipped by your bank's clients to Iran, as a risk management measure.
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