13 June 2023  

Will Lebanon be on the Grey List of FATF?

– What is the Grey List?
– Who has the right to put a country on a Grey List?
– What are the implications of being on the Grey List?
– How to take off a country from the Grey List?

I answered these questions in this quick interview.

#inanutshellbymj #marijosamneh #fatf #compliance #amlcompliance

11 May 2023  

Cyber Crime through emails

Cyber-crime through emails – In a Nutshell.

Being the victim of Cyber-crime is not a matter of “If”, it’s a matter of “When”.
So be prepared, as you might be the next one targeted!
Awareness remains the first line of defense.

#cybercrime #inanutshellbymj #marijosamneh #compliance
14 March 2023  

Companies owned or controlled by a “Sanctions Target” – by Marijo Samneh

When opening an account for an entity, it is important to know who is hiding behind it, in order to avoid working with sanctioned persons.
Therefore screening the names of the Ultimate Beneficial Owners is a must, prior to opening an account. If the company is owned or controlled by a sanctioned person, the account can clearly not be opened.
Which companies are considered owned or controlled by a “Sanctions Target”?
As per the EU laws, if a sanctioned person possess more than 50% of a company, the latter is considered owned by a “Sanctions Target”.
As per the US laws, if a sanctioned person possess 50% or more of a company, the latter is considered owned by a “Sanctions Target”.

#sanctions #sanctionscompliance #compliance #inanutshellbymj #marijosamneh
19 January 2023  

Nesting – In a Nutshell

Nesting – In a Nutshell

Nesting is the bank’s misuse of its relationship with correspondent banks, by carrying out transactions for other banks’ customers, when the other bank could be located in a country that is subject to sanctions and embargoes, or rated as a high risk country. Therefore, main correspondent banks around the world avoid dealing with such banks.

#aml #amlcompliance #compliance #marijosamneh #inanutsehllbymj

15 December 2022  

Dormant or Frozen Account

Frozen Accounts
Accounts are considered frozen or dormant when no transactions are carried out for a certain period of time.
After this period, which are determined by the regulator or the institution’s internal policies, the account must be considered frozen or dormant.

Dormancy periods are usually different, depending on the type of account; current accounts, deposit accounts etc.

Risks from dormant accounts are high, due to the possibility of internal fraud, rather than money laundering.

There is the possibility that one of the bank’s employees could be aware of the account, and see an opportunity to take advantage of the dormant account through a fraud scheme.

#compliance #fraud #inanutshellbymj #marijosamneh #amlcompliance