Recent Regulatory Guidance – Know Your Customer’s Customer

December 3, 2020 11:15am

Allie Cheatham
Senior Vice President
Brown Brother Harriman

Ilya Schulman
Executive Director, Global Financial Crime Counsel
JPMorgan Chase & Co.

Jeanine P. McGuinness

  • OFAC Guidance related to the maritime Industry, energy and metals sectors, and related communities (including financial institutions)
  • Supply Chain: importance of conducting due diligence on an organization’s customers, supply chain, intermediaries, and counter-parties. The recent designation of XPCC in China presents challenges for U.S. companies as they try to determine potential involvement of XPCC subsidiaries in their transactions
  • Human Rights: New global regulations
  • Humanitarian Assistance: Numerous OFAC general licenses that permit the exportation to sanctioned jurisdictions of agricultural commodities, food, medicine, and medical devices and various humanitarian assistance, parties must take care to avoid involvement in transactions that may benefit sanctioned regimes or SDNs