Read the CySEC Circular C622
Memo #10-2024
CySEC Circular No: C622
Date: 06/03/2024
Subject: U.S. Sanctions Guidance
Purpose: To inform the Regulated Entities that the OFAC issued a Sanctions Advisory.
In Summary:
CySEC has issued the Circular C622 on 05/03/2024 to inform the CIFs, ASPs, UCITS Management Companies, Internally managed UCITS, AIFMs, Internally managed AIFs, Internally managed AIFLNPs, Companies with sole purpose the management of AIFLNPs, Crypto Asset Service Providers and the Small AIFMs under Law 81(I)/2020, that the Office of Foreign Assets Control (OFAC) issued on 22/12/2023 a Sanctions Advisory titled “Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base” (the ‘Sanctions Advisory’).
The Sanctions Advisory provides practical guidance to foreign financial institutions on how to identify sanctions risks and implement corresponding controls.
With this Circular C622, CySEC urges Regulated Entities to review and consider the provisions of the Sanctions Advisory, when implementing due diligence measures, especially for ongoing monitoring of accounts and transactions and risk-based controls to mitigate sanctions risks.
Furthermore, CySEC draws the attention of Regulated Entities to Circulars C337 and C475 regarding the OFAC’s Specially Designated Nationals And Blocked Persons List (the ‘SDN List’), which is updated regularly, when assessing the money laundering and terrorist financing risks associated with business and client transactions.
This Circular C622 also refers to a number of useful links that Regulated Entities should consult on an ongoing basis.
The OFAC’s Sanctions Advisory can be found on the following link: https://ofac.treasury.gov/media/932436/download?inline
Read the CySEC Circular C622
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