In the past several weeks, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) has added hundreds of names to the sanction list from all over the world. The U.S. Department of Commerce has also added new names that are essential for suppliers to be aware of and screen against.
A significant portion of this new sanction activity is related to Russia, though an increasing number of sanctions continue to also target illicit drugs, corruption and Iran as geopolitical tensions rise in the Middle East.
And while screening against government lists is required, broader risks start to emerge beyond standard sanctions screening when considering sanction evasion and associated key enablers.
It can be difficult to discern potential risks to your institution and operations without broader risk screening, particularly as it relates to jurisdictions or transshipment hubs that are higher risk regarding sanctions (e.g., determined via regulatory guidance or industry reporting). While not exhaustive, U.S. Treasury has provided guidance on this topic through a series of alerts. Further guidance can also be found here. In line with this guidance, your institution may also benefit from knowing and reviewing financial secrecy hubs, as well as countries engaged in a higher level of trade with Russia (e.g., India more recently) and those named by the Financial Action Task Force which can be found here.
OFAC’s expectation of how an institution conducts diligence has historically been “reason to know” or “reason to believe” - a burden that has only increased as more data than ever has become available and usable at scale. An area where this is particularly true, is media and NGO-driven reporting, which is rich with information and intelligence that when stitched together tells a more contextualized story.
Take for example, Dmitry Mironov.
He is not sanctioned. He does not appear when you search his name on the OFAC website.
However, he certainly presents sanctions-related risk that is important to understand as part of your comprehensive sanctions program, as well as your institution’s general risk-based approach.
According to the Organized Crime and Corruption Reporting Project (OCCRP) and other media and official reporting, he has become one of Russian President Vladimir Putin’s closest advisors. Responsible for Kremlin personnel, as well as a number of other “special projects”.
His brother, Evgeny Mironov, has stakes in a number of companies whose fortune has dramatically improved in recent years, thanks in part to family access to Moscow. The same can be also said for his father, Yuri Mironov.
Basic open source research shows that Dmitry Mironov has historically had access to Vladmir Putin, including recently as evidenced in this photograph published on the Russian presidential website (taken in 2018). And the recent reporting also illustrates that these links are likely still strong.
How confident are you that your institution is not working with Dmitry Mironov, his immediate family or any of their companies? What does your screening solution return when you search his name? And if you are working with them, have you carefully considered the risk of doing so?
Associated individuals found in public reporting:
Dmitry Mironov
Evgeny Mironov
Yuri Mironov
SK RusTrest
Specialized Developer Desna
Technospetsstroy
The truth is, your system and content providers are unlikely to make these joins and display this information. However, these are precisely the type of connections that matter and that well resourced institutions are likely to flag that your institution may rely upon to conduct global business.
An advantage of the Sigma360 platform is the cross-cutting, fully integrated connection of global data to see and get ahead of these risks in your screening operations. This enables teams to be on the front foot, while considering both external and internal data in real time.
Summary
Leveraging sanction lists and automating your approach to sanction screening is essential to meeting regulatory requirements and expectations. However, requirements and expectations are changing and changing fast. The Sigma360 platform allows your firm to operate at the highest level, out-of-the-box and without the need for lengthy system deployments or maintenance.
Get ahead of risk, and ensure you are not reliant on systems of the past in efforts to meet the challenges of today and the threats of tomorrow.
To find out more about Sigma360’s approach to advanced adverse media capabilities please request your demo today.
How can Sigma360 help me stay ahead?
Using Sigma360's risk decisioning software platform, organizations can not only get ahead of risk, but leverage unstructured data - like the screening examples highlighted in this article.
Below are key resources and recent guidance related to OFAC compliance, sanctions programs, and risk mitigation.
Meeting regulatory expectations - particularly with the...
Ensuring that your organization has in place a...
