Sanctions go super-sonic

It’s funny, anti-money laundering training.  You notice a new topic and you start to include a couple of slides about it – people are a bit bemused, but being lovely polite delegates they let you get away with it.  Then it becomes more current, and so you expand it into its own little session.  And then wham! it’s all anyone wants to talk about.  It happened once upon a time with white collar crime, which is now out of fashion again – not the crimes, which are burgeoning thank you very much, but the training about them.

At the top of the tree at the moment are two hot topics: anti-bribery legislation (which I have blogged about several times recently), and sanctions.  A couple of years ago, sanctions took up about one slide of a presentation: there are sanctions, they’re a bit boring, but make sure you check them.  Now – phew-eee!  We have sanctions to our eyebrows and beyond.  We have sanctions from the US, the UK, the UN and – for all I know – U2 (well, that Bono does get irate about things).  And we have to comply with them Or Else – the penalties are severe in terms of both money/prison, and reputation.

What makes this all the more scary is the speed with which sanctions change.  Most sanctions refer to a list of sanctioned individuals and organisations, and this can be updated on a daily, even hourly, basis.  The recent “Arab Spring” has been a good example of this, with regimes coming into and going out of favour almost before we’ve learnt how to spell them.  And the death of Gaddafi of Libya will doubtless result in a rejigging of the sanctions relating to that jurisdiction, its rulers, its inhabitants and its diaspora.  Certainly those who lived under the protection of Gaddafi will be looking to their future – and how to finance it.

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