If you happen to be a compliance professional in South Africa, responsible for AML/CFT, you should be aware that your country's banks, as well as nonbank financial institutions (NBFI) face terrorist financing threats on a level higher than those that exist elsewhere. The fact is, a number of specially designated global terrorist entities, as well as entities that feed funding to those internationally-sanctioned organizations, are not sanctioned or prohibited there. In truth and in fact, some are tolerated or even welcomed for political or social reasons.
Given that financial institutions function on a global scale, when they even unwittingly conduct transactions which facilitate terrorist organizations, even indirectly, they risk consequences from those Western countries that maintain sanctions against them. These include taking action against local branches or subsidiaries located abroad, regulatory action imposing civil fines and penalties upon such entities abroad, up to and including the complete blocking of access to critical financial centers or currencies in the most serious cases. This could occur, even though there are no existing legal obstacles to processing such financial transactions within South Africa.
It is incumbent upon compliance officers working in South Africa to be aware of the specific entities which could damage their bank or their clients, in the event that regulatory agencies abroad determine that terrorist financing impacting their national interest, occurred or originated within the South African financial community. As this information is obviously of a sensitive nature, and not generally suitable for publication, it will be detailed at the upcoming TITC seminar "UNMASKING AFRICA'S FINANCIAL UNDERWORLD," on February 19 and 20. You are urged to attend this important event, as an important component of your responsibilities to counter the financing of terrorism, and to reduce your level of risk.
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