A cornerstone of a New Zealand AML/CFT Risk Assessment is identifying the different countries your business interacts with through its customers and transactions. In assessing the risk posed by each country, and depending on the nature of your business’ interaction with different jurisdictions, it is essential to take into account whether any of those countries are subject to any global sanction regimes.
The above diagram was drawn up by the US Treasury Department to show how the existing global sanction regimes from the US, UN, and EU, the major global compliance players, interact and overlap. This provides a handy guide for New Zealand businesses assessing the risks posed by countries it interacts with.
A form of global sanctions have been around since 1917, when the US passed the Trading With The Enemy Act which allowed a domestic administrative body to draw up a “Black List” of foreign nationals who were blocked from doing business in the US. Since then, sanctions have evolved into a regime of penalties imposed on countries or organisations in order to apply foreign policy or economic pressure.
While the foreign policy or economic relationships between other countries and organisations may not always be directly relevant to New Zealand,in this ever-increasingly connected world, it will always have a bearing on how New Zealand and its businesses choose to interact with others on the global stage.
Need some more information about how the global sanctions regime could affect your AML/CFT Risk Assessment? Contact Fiducia on firstname.lastname@example.org or +64 21 256 1641