COMMERCIAL OPERATIONS IN TURKEY: ASSESSING EXPOSURE TO ISLAMIC STATE, AL QAIDA, AND OTHER ARMED GROUPS IN IRAQ AND SYRIA

Published by The Camstoll Group, January 15, 2015

A review of Islamic State and al Qaida-related activity in Iraq and Syria provides insights on cities, banks, and business sectors in Turkey at greater risk of exposure to illicit commercial and financial transactions. Islamic State and other armed groups that control or profit from oil fields and oil trade in Syria and Iraq generate revenue from sales to Turkey-based consumers and middlemen, according to government and media reports. Turkey has also been identified as a transit point for foreign fighters and as a fundraising hub for relief operations that have been associated with al Qaida.

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US TARGETS IRANIAN BANKING OUTPOST IN MOSCOW

Published by The Camstoll Group, November 4, 2014

A review of the US designation of Asia Bank provides insight on financial sector exposure to Russia-based Iran risk, particularly with respect to Iran’s demand for foreign currency.

On August 29, 2014, the US government sanctioned Iranian-owned Asia Bank for providing financial services to the Central Bank of Iran. Asia Bank, formerly known as Chemeximbank, is based in Moscow. The designation of Asia Bank marks the first time that the US has sanctioned a Russia-based financial institution under Executive Order 13622 –– which prohibits certain financial dealings with Iran.

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Social Media & Illicit Finance: A Look at the Conflict in Syria

Published by The Camstoll Group, August 11, 2014

Financial facilitators are increasing their use of social media platforms such as Twitter and Facebook to raise funds for designated terrorist organizations and other militant groups operating in conflict zones. Financial institutions should consider whether their financial intelligence and analytical capabilities are fashioned to effectively monitor social media for data relevant to AML/CFT risk management....

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Gennady Timchenko & Volga Group Adapting Business Following U.S. & Canadian Sanctions

Howard Mendelsohn
Published by The Camstoll Group, July 17, 2014

In March and April, the US government sanctioned Russian businessman Gennady Timchenko, his Luxembourg-registered holding company Volga Group, and ten related subsidiaries. Timchenko was identified as a “member of the Russian leadership’s inner circle,” whose involvement in the energy sector was “directly linked to [President] Putin.”

To date, Canada has sanctioned Timchenko, Volga Group, and nine Volga Group subsidiaries. The European Union has not acted against Timchenko or Volga Group....

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Crimea sanctions highlight compliance risk in Russian energy sector

Ben Davis and Howard Mendelsohn
Published by The Camstoll Group, June 2, 2014

On May 12, 2014, the European Union added two Crimea-based energy firms to its Russia sanctions list: Chernomorneftegaz and Feodosia Enterprise (aka Feodosia Oil Product Supply Company or “Feodosia”). The sanctions were levied in response to the expropriation of the companies by the separatist Crimean government in March 2014. To date, the United States and Canada have sanctioned Chernomorneftegaz, but not Feodosia.

Both companies were previously controlled by the Ukrainian government...

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