Compliance: CNAS’ Stern Warning to Banks, “Avoid Sanctioned Entities”
The Centre for a New American Security (CNAS) in partnership with Compliance Institute Nigeria (CIN) has concluded a two-day in-depth workshop on North Korea Sanctions and Counter-Proliferation Compliance for compliance officers in Nigeria, chiefly made up of compliance officers of banks and other financial institutions.
The CNAS two-leg event which held in Lagos – 21st and Abuja 22nd saw presentations on North Korea business activities in Africa and typologies of North Korean sanctions evasion tactics, foundations of effective sanctions compliance relevant across sanctions programmes. It impresses on the use of Publicly Available Information (PAI) in sanctions compliance and enforcement.
Speaking on the rationale behind the workshop, Peter Harrell, leader of the CNAS delegation and former diplomat with the US state department who has garnered extensive experience on sanctions and terrorism finance issues, explained that the workshop in Lagos and Abuja are part of a series of workshop being organized around the world to help educate government officials in the private sectors on sanctions issues particularly around North Korea and other sanctioned or red flagged nations.
“It’s a global effort to increase knowledge about the issues, to make the workshop informative for banks on how to deal with compliance issues on a day to day basis and how to avoid getting in trouble with regulators – UN sanctions and the FATF recommendations” Mr.Harrell revealed.
Claiming that sanctions are valuable to protect international security and peace, but it only work if banks and companies know what they are suppose to do. Hence, the series of the CNAS workshops which offer training on the subject of terrorism funding and threats to global peace.
The last 15 years have seen sanctions either by United Nations, European Union or America have become a tool against North Korea nuclear program; Syrian crisis among others. The purpose of this workshop is for banks to be able to take recommendations and implement them so they will be able to show their correspondents, “we meet the compliance standard expected of us”.
Disabusing the mind of some participants of the fear of loss of business by turning their backs on some businesses tagged as dirty money, Harrell says there is no amount of money gained that could compensate for threats to global peace and security.
Speaking on the motive of the CIN – CNAS workshop, President, Compliance Institute, Nigeria, Pattison Boleigha, said is that at the end of this whole thing, “we will learn better way of identifying those sanctions that various entities like United Nation, European Unions and the US have placed on certain entities or countries.
According to the CIN President, it will also make us and our organisations better compliance platforms to avoid our institutions being used to do illicit trade or activities by or for sanctioned organizations.
The workshop for him wouldn’t have come at a better time to throw light on these crucial issues around global peace.
In simple terms, the President breaks down the sessions thus: “There are comprehensive sanctions and limited sanctions as we already know such as North Korea sanctions, Iranian sanction, Sudan Sanctions and there are other designated entities that have been sanctioned. It also afforded us data bases for all of these so we are now in a better place to know how those sanctioned entities try to dodge the sanctions and use our institutions to do those transactions”.
We have been asked not to process transactions on any entities or countries that have been sanctioned such as Cuba, Mahama etc the most important thing is that we are not expected as financial institutions to facilitate any transaction that is going to any of those sanctioned countries.
With Nigeria signed to the UN as one of the signatories to the resolution to sanctions, organisations in the country are forbidden to transact any business whatsoever with sanctioned entities or nations otherwise the country risks being added to that list and you be banned from doing any transaction with the US or any European country.
Warning that no organisation can survive in this part of the world as a financial institution without correspondent banking relationships with the outside world, he noted any contravention may lead to severance of those relationships. “If your correspondent bank finds out you are violating the US Sanctions and UN sanctions, they would stop providing correspondent banking service to you. Show me a bank that cannot provide correspondent banking transactions to their customers and are still alive” he retorted.