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ACAMS moneylaundering.com 24th Annual International AML & Financial Crime Conference - Hollywood

C32 - Know Your Country: Managing the Complications of Venezuelan Sanctions

Apr 16, 2019 4:50pm ‐ Apr 16, 2019 5:50pm


• Crafting unique Venezuela oversight systems, using resources such as Treasury’s Venezuela sanctions updates and promptly incorporating OFAC changes involving SDN List, blacklisted entities and assets linked to PEPs

• Conducting risk-based customer reviews to identify potential sanctions-related risks such as purchases of banned debts or accounts receivable owed to Vmulenezuela or PDVSA or invoice manipulation of otherwise permissible trades

• Reviewing FinCEN advisory on Venezuelan corruption to identify red flags such as government contracts with entities having no clear business purpose, unusually complex wealth management patterns and real estate purchases incommensurate with official salaries


  • Kimani Rogers, CAMS, Executive Director – Global KYC Audit Manager, JPMorgan Chase & Co.


  • Melissa Leeds, CAMS, Data Mitigation Support Specialist, Far Ridgeline Engagements, Inc.
  • Brian O'Toole, CAMS, Senior Vice President, Director of Sanctions and Screening, BB&T, Now Truist
  • Celina B. Realuyo, Professor of Practice, William J. Perry Center for Hemispheric Defense Studies, National Defense University
  • Michael Zytnick, Director, Head of Sanctions Office, Americas, Deutsche Bank

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