Negin Ajam
Senior AML Legal Expert
Advanced LL.M. in European and International Human Rights Law
Veröffentlichte Artikel
Identifying suspicious activities is a cornerstone of combating money laundering, helping Obliged Entities (OEs) detect and deter fraud and other illicit activities. To this end, OEs must closely monitor high-risk criteria to flag transactions or behaviours that deviate from standard patterns. All red flags should be investigated to determine whether they represent legitimate transactions or warrant further scrutiny.
The proliferation of unilateral and secondary sanctions has led to a concerning trend of overcompliance by businesses, particularly banks and financial institutions. Overcompliance refers to excessively restrictive practices that go beyond the requirements of sanctions regulations.
With the recent adoption of the EU’s 13th sanctions package against Russia, we sought insights from our senior legal officers at Wiacon, Negin Ajam and Nasim Zargarinezhad.
The EU’s decision to sanction Chinese firms, among others, aims to disrupt the supply chain of vital drone components to Russia, especially given the ongoing conflict in Ukraine.