6. The sanctions landscape becomes even more complex
2018 was a year in which financial sanctions were employed extensively across the globe – so much so that their effectiveness may have diminished. On the targeting of Iran, former White House Official, Richard Nephew, stressed the need for sanctions to have “a compelling story”, specifically referencing the need for clear targets and objectives in ensuring compliance.
With that in mind, we predict that 2019 may see this landscape grow even more complicated. Against the backdrop of the Iran sanctions, Europe, Russia, and China might continue to try and create an alternative financing channel. If successful this will add a new level of legal complexity for anyone doing business with the country.
As a further challenge, that complexity must be managed alongside the recent targeted sanctions the US and Europe placed on Russia. The thawing of US relations with North Korea also looms in 2019 – but is unlikely to affect sanctions in place until diplomatic talks resume. A late arrival on the sanctions radar is Saudi Arabia: diplomatic outrages including the murder of Jamal Khashoggi, and the peculiar actions of Crown Prince Mohammed bin Salman, could easily prompt Western powers to respond with sanctions in 2019 – with significant consequences across a spectrum of industries.
Tip: Making sure that you can screen your client base for changes to sanctions in near-real time will be crucial to remaining compliant in 2019. Ask your data provider how quickly they include changes from essential lists like OFAC in their database, and how quickly you’ll be alerted to changes in your customer’s risk.
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