R&C: Could you provide an overview of sanctions enforcement in the Asia-Pacific region? To what extent are regulators becoming more sophisticated, and stepping up their monitoring and enforcement efforts?

Wysong: Regulators in countries such as China, Hong Kong and Singapore are increasingly focused on the role that financial institutions play in detecting and reporting financial crime in the areas of sanctions, money laundering and bribery and corruption. Regulators have high expectations for the design and execution of sanctions controls, whether in banking, securities, insurance, or other sectors. This means hiring more staff and investing more resources in sanctions screening and training. Meanwhile, US regulators, at both the federal and state levels, have sharpened their focus on Asia-based financial institutions and corporates. New York State, in particular, has recently announced two major enforcement cases involving anti-money laundering and sanctions violations against Asian banks. The Office of Foreign Assets Control (OFAC) and the Department of Justice (DOJ) also recently took action against a China-based corporate and several individuals for dealings with North Korea. Other investigations are in the pipeline. These cases underscore the increasing enforcement risk for companies in Asia, as well as a more aggressive regulatory and enforcement posture on the part of sanctions authorities.

Jan-Mar 2017 Issue

Clifford Chance

Deloitte Risk Advisory Pty Ltd


Norton Rose Fulbright LLP