Tuesday, April 14, 2015


I do not like it*, but it appears that it will soon become a reality, and therefore, a commercial solution must be created. I am referring to the serious compliance problem that will soon be encountered by American companies that will soon be arriving, en masse, in Cuba, after the lifting of the American designation of the Republic of Cuba as a State Sponsor of Terrorism.

As I have previously stated, notwithstanding the required Cuban guarantees, about its termination of support for SDGTs, they will still be in residence, and in transit into and through Cuba. As such, American companies might just have some goods or services that certain terrorist organizations need, and thus the clear and present danger that a US corporation will, unwittingly, do business with a sanctioned organization, through its officers and agents, should be taken very seriously.

Therefore, since there is no commercial-off-the shelf database of known members of ETA, FARC, ELN, Hamas, Hezbollah, and the other terrorist groups who have been known to have agents living, working, or doing business in, Cuba, and the US Government will not tip its hand by revealing that it knows most of their names, it is time for the commercial sector to step up, and create such a database, for sale to compliance officers serving American companies who wish to trade with the new Cuba, as well as their bankers, suppliers, vendors, and other related entities who will potentially be exposed to doing business with terrorists.

Demand drives the commercial database market; remember, when American regulators ruled that businesses were required to obtain information about a sanctioned Iran that was "knowable," and World-Check created, and made available, a database that contained the necessary information. We need a company in the field to build an accurate database of the names of members of terrorist organizations, whose agents are known to be operating in the Western Hemisphere, and make it available to the compliance community. Otherwise, some US companies are liable to get badly burned, with providing material support to terrorism charges.
*Removing Cuba from list of State Sponsors of Terrorism exposes American Businessmen

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