Sunday, May 14, 2023


Cadillacs in the Ural Mountains?

Inasmuch as there has been an explosion of international sanctions evasion regarding Russia, involving transshipments of high-end goods from the UAE, and the United States apparently has increased its surveillance of such activities of late, US financial institutions are advised to insist upon End User Certificates regarding payments for major shipments to Dubai.

While American law enforcement agencies are focused upon dual-use products which have military applications, do not for a moment think that US banks can allow those of their clients who are exporters to the Middle East to ignore doing all they can to guard against reshipment to Russia. look at all the articles about new American and European cars ending up in the hands of Russian consumers.

It is humbly suggested that bank compliance officers obtain End User Certificates when being asked to accept large funds transfers from the UAE, where your bank client is a manufacturer or distributor of significant consumer goods. Have a senior officer of your bank client sign the document, NOT the UAE company, and insist that the company's compliance officer also attest to its accuracy, by adding his signature. That way, should there later be a regulatory or law enforcement investigation, you have two parties that they can direct their inquiries to, instead of your bank.

If your bank client cannot, or will not, sign such a document, prepared by your legal counsel, decline to process their payments from the UAE. Otherwise, you may end up holding the bag for your clients' willful blindness to sanctions.

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