Greater Clarity With Standing Humanitarian Exemption Across All Sanctions Regimes
Association of Certified Sanctions Specialists
Kaley Schafer spoke to the Association of Certified Sanctions Specialists about how the aftermath of the Taliban's return to power in 2021 affected humanitarian activities in Afghanistan, which therefore, led to financial institutions "de-risking" their Afghanistan operations and "delaying or blocking" funds intended to support humanitarian assistance. Kaley noted, "Despite statements from FinCEN and the federal functional regulators indicating that not all customers pose the same level of risk and that there is no need to de-risk customers categorically, financial institutions still face potential scrutiny from examiners in providing products and services to certain types of customers. The actions and beliefs of individual examiners often can be more important than high-level policies set by their agencies."
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