Friday, March 29, 2013


If you are watching the strong response that the United States took to the latest North Korean provocations, sending B-2 bombers over Korea on a training bomb run, you know that the DPRK is now a priority issue with the American Government. Prudent compliance officers always adjust their policies and procedures to unfolding events.

Since both the US and the UN have imposed new sanctions upon North Korea, you will want to take a hard look at any transactions your clients have with that country. I understand that charitable clients, NGOs and clients with OFAC licenses are generally low risk, but proper procedure requires that you ensure that there is no chance your bank is involved in any transactions that Treasury will look upon as technical violations.

Frankly, I see no reason why you should be comfortable, given the North Korean posturing, and threats against the US, with any exposure there, as there is little to be gained, and a lot at risk. This also means watching potential transfers to North Korea through third parties; watch yourself on indirect transactions.

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