ANALYSIS: Politically Exposed Persons – defining who exactly they are and why a European central PEPs registry makes sense

Regulatory Watch News

• 

  Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and State Street Bank and Trust Company and its subsidiary, Charles River Systems, Inc.

  OFAC

  July 26, 2024

  The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced a $7,452,501 settlement with State Street Bank and Trust Company (State Street), a Massachusetts-based financial institution, on behalf of itself and its subsidiary, Charles River Systems, Inc. (Charles River).  State Street agreed to settle its potential civil liability for 38 apparent violations of OFAC's Ukraine-/Russia-Related sanctions.  The apparent violations involved invoices that were redated or reissued by Charles River between 2016 and 2020 for certain customers who were subject to Directive 1 of Executive Order 13662, as well as certain payments outside of the applicable debt tenor accepted by Charles River from these customers.  The settlement amount reflects OFAC's determination that the apparent violations were not voluntarily self-disclosed and were egregious.  For more information, please visit the following web notice and settlement agreement.

• 

  FinCEN Issues Notice to Financial Institution Customers on Beneficial Ownership Information Requirements

  FinCEN

  July 26, 2024

  Today, the Financial Crimes Enforcement Network (FinCEN) issued a notice to customers of financial institutions about reporting beneficial ownership information. The Corporate Transparency Act requires certain entities, including many small businesses, to report to FinCEN information about the individuals who ultimately own or control them. A separate regulatory requirement currently requires many financial institutions to also collect beneficial ownership information from certain customers that seek to open accounts as part of Federal customer due diligence requirements. Today’s notice provides answers to key questions about: (1) reporting beneficial ownership information to FinCEN under the Corporate Transparency Act (https://www.fincen.gov/boi); and (2) providing beneficial ownership information to financial institutions in connection with Federal customer due diligence requirements. FinCEN encourages financial institutions to share this reference guide with customers that may be required to report beneficial ownership information.

• 

  Slovakia: EPPO opens investigation into attempted fraud concerning waste treatment plant

  European Public Prosecutor's Office

  July 26, 2024

  (Luxembourg, 26 July 2024) – This week, the European Public Prosecutor’s Office (EPPO) in Bratislava (Slovakia) opened an investigation into attempted EU funding fraud involving the construction of a waste treatment plant in Iža. On 20 December 2022, a grant agreement for a non-refundable financial contribution (NFC) was concluded between the Ministry of the Environment of the Slovak Republic, represented by the Slovak Environmental Agency, and the beneficiary – a construction company - for the building of a waste treatment plant. The approved grant amount was €1 416 100, fully financed by the EU’s Cohesion Fund and representing 50% of the total cost of the construction amounting to €2 832 200.