DIFFERENT ANGLE by Kenneth Rijock
Reliable sources have indicated that President Bush will announce some type of sanctions against Venezuela on Wednesday. It is not known whether this will involve OFAC listing of financial institutions and their owners, US visa revocations, the designation of certain Venezuelan entities and individuals, or the naming of government-controlled companies. Whatever does occur could seriously disrupt the ability of the named designees to conduct financial transactions, as they will thereafter be denied access to the US financial structure. They may also have US-based funds and assets frozen by Treasury.
US Regulators may take a dim view of the fact that a freeze order was served upon your bank, only to learn that you approved the transfer, hours earlier, of the money, into a known tax haven jurisdiction. It might make the agency involved decide to take a hard look at your compliance policies and procedures, including a "look-back" of a couple of years. Since your institution may not have properly vetted the Source of Funds for the since-departed cash, you might have a problem.
Ensure that any large funds transfer request that seems to be outside the normal course of business, and involving known Venezuelan nationals, or companies in which they have an interest, gets a good look.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Please take note of the following content change to be applied to the Data-File on 19 December, 2008. In order to avoid any potential problems please ensure that your datab...more


SEND ARTICLE TO A FRIEND
