Tag: Silvia Surman

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Compliance Kitchen

Understanding the Beneficial Ownership Information Filing Requirement Starting in 2024

Are you aware of the upcoming beneficial ownership information filing requirement that will start in January 2024? The Financial Crimes Enforcement Network (FinCEN) issued their first set of guidance materials, aiming to help individuals and small businesses understand the incoming filing requirement. According to the guidance, “beneficial ownership information” refers to individuals or individual who directly or indirectly own or control a company.

To enhance corporate transparency and discourage illegal activities like money laundering, companies must report the beneficial ownership information to FinCEN. The guideline applies to domestic and foreign reporting companies, including corporations, LLCs, or any other legal entity that was created by filing documents with a secretary of state or similar body. However, exemptions are available, and there are 23 different types of entities exempted from the requirement.

To ensure a smooth transition, FinCEN has put together an online platform for reporting and published frequently asked questions on their website along with an introductory video on YouTube. If you’re a business owner or operate a legal entity registered to do business in the U.S, it’s essential to start preparing for the beneficial ownership information filing requirement.

Here are three tips to keep in mind:
– Stay updated with the latest guidance materials available on the FinCEN website.
– Ensure that you have all documents and information needed to report beneficial ownership information accurately.
– Identify whether you qualify for any exemptions and seek professional advice if needed.

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Compliance Kitchen

The Compliance Kitchen Unveils the EU Sanctions on Russia and Explores the Impact

In The Compliance Kitchen podcast, host Silvia Surman dives into a variety of compliance topics. In this episode, Silvia examines sanctions on Russia imposed by the European Union, including asset freezes, travel bans, blocking access to Russia’s central bank reserve holdings, and prohibitions on exports of dual use goods and technology, among other sanctions. Silvia also takes a look at how two thirds of the world population is taking a neutral stance on the situation and the economic impact of the sanctions thus far. She references an article from the European Parliamentary Research Service for viewers to explore further. Join Silvia on The Compliance Kitchen to stay up-to-date on international compliance topics.

Key Highlights

EU Sanctions on Russia [00:07]

Impact of International Sanctions on Russia [05:43]

Impact of G7 Sanctions on Russia’s Economy [11:12]

Accessing European parliamentary research services [16:35]

Notable Quotes

  1. “Whatever you hear on compliance kitchen is not legal advice, and it should not be used as such.”
  2. “Then we had the attempted poisoning of Sergei Skripal and his daughter, they were living in the UK at the time. That was in 2018. So you continued to respond to all these acts with some degree of sanctions or some sanctions regimes that they implemented.”
  3. “Then we had the Alexandre Navalny poisonings that was in 2020, 2021. So with that came the EU global human rights sanctions regime.”
  4. “Banning transactions with certain Russian state owned military industrial companies disconnecting leading Russian financial institutions from the Swift system.”
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Compliance Kitchen

Compliance Kitchen on Unwrapping the Cloaked: How Russian Oligarchs Evade Sanctions with the Help of Enablers

The Compliance Kitchen, hosted by Silvia Surman, dives into detailed and complex topics looking at all sides of the compliance industry. The recent advisory from the repo task force that Silvia discusses reveals the clever evasion tactics used by Russian elites, including the beneficial ownership of legal entities transferred to their children, as well as enablers performing certain functions on their behalf. Russian and other users are able to access sensitive goods and technologies by using freight forwarding businesses in a third country. The Compliance Kitchen is here to provide insight and analysis into these and other compliance topics in an engaging and educational manner.

Key Highlights

Russian Sanctions Evasion Tactics Used by Elites. 00:06

The Use of Enablers to Avoid Sanctions on Russian Oligarchs. 06:13.

Illegal Access to Sensitive Goods and Technologies Through Freight Forwarding Business. 12:18

Notable Quotes

  1. “This is a multilateral effort that has used information sharing and coordination to isolate and pressure sanction Russian individuals and entities.”
  2. “The typologies that they identified in this advisory include the use of family member burs and close associates to ensure continued access and control over assets.”
  3. “The asset transfers it’s being observed that go to family members and close associates sometimes occur immediately before a person is on sanctions list or shortly thereafter. So that indicates sanctions evasion efforts.”
  4. “More specifically, the advisory tells us that sanctioned Russian individuals and entities have used the use of expensive real estate to hold value or to own their illicit proceeds through real estate using complex ownership structures to avoid identification of the ultimate beneficial owner.”
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Compliance Kitchen

Compliance Kitchen on Navigating the 10th Package of EU Sanctions and DOJ’s Disruptive Technology Strike Force

The Compliance Kitchen with host Silvia Surman is the podcast you need to stay up-to-date on regulation details. In the most recent episode, Silvia dives into the EU’s tenth package of sanctions against Russia and the DOJ’s new disruptive technology strike force. Surman covers details such as entities and people added to the Russia sanctions list, additional trade restrictions, enforcement and anti-convention measures, and the prohibition on transmitting dual use items and goods and technology from the EU through Russian territory. Additionally, Surman talks about the DOJ’s new strike force encompassing more than 10 cities to enforce U.S. laws protecting advanced technologies from illegal acquisition. Tune into The Compliance Kitchen for the need-to-know information on regulation details!

Highlights Include

  • EU Sanctions
  • DOJ Disruptive Technology Strike Force

Notable Quotes

  1. “The EU has added a number of entities and people to the Russia sanctions list.”
  2. “Also those who continue to press the Kremlin’s propaganda and spread this information in the media.”
  3. “The goal is to prevent critical technologies from being acquired or used by certain nation state adversaries such as China, Russia, North Korea, and Iran.”
  4. “This is a joint venture that encompasses more than 10 cities and aims to enforce U. S. Laws to protect advanced technologies from illegal acquisition and used by certain nation state adversaries.””

Resources

Silvia Surman on LinkedIn

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Compliance Kitchen

Compliance Kitchen – Navigating OFAC’s Latest Guidance on Russia’s Metals and Mining Sector

The Compliance Kitchen, hosted by Silvia Surman, is a podcast that examines and evaluates the changing legal framework of international compliance. In this episode, Silvia examines OFAC’s brand new determination concerning the metals and mining sector of the Russian Khanate. She provides listeners with an FAQ about the determination and explains that it authorizes certain energy-related transactions or if General Licensed 6C only authorizes those activities. Silvia further elaborates that the license authorizes transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. Tune into Compliance Kitchen to stay updated with the evolving legal framework of international compliance.

Notable Quotes

1. “This February 24 determination authorizes sanctions on any person that the government determines to operate or have operated in the metals and mining sector of the Russian economy.”

2. “OFAC does not intend to target persons for operating in this metals and mining sectors where the provision of their goods and services is solely for safety and care of personnel protection of human life, prevention of accidents or injuries, maintenance, necessary repairs, to avoid significant or environmental damage or activities that are related to environmental mitigation or remediation.”

3. “Non-US persons generally do not risk exposure to US blocking sanctions. Under executive order 14024 for engaging in transactions with black persons, including in the metals and mining sector where those transactions would not require a license if a US person were engaging in the transactions.”

4. “Non-US persons generally do not risk exposure to US blocking sanctions if they engage in transactions in the mining and metals sector. If General License 8F would normally authorize such transactions as in Frank. That 1 authorizes certain energy-related transactions or if General would only authorize those activities Licensed 6C. That license authorizes certain transactions related to the production, manufacturing, sale, transport, or provision of medicine, medical devices, including certain industrial isotopes used in nuclear medicine.”

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Compliance Kitchen

Compliance Kitchen – The Changes in the DOJ Corporate Enforcement Policy

The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman visits the DOJ revised its Corporate Enforcement Policy and the Kitchen looks at the highlights.

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Compliance Kitchen

Compliance Kitchen on Prolonged EU Sanctions on Russia and More

The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman looks at the EU prolonging economic sanctions over Russia’s military aggression against Ukraine; FinCEN designates virtual currency exchange Bitzlato a “Primary Money Laundering Concern” for illicit Russian finance; DOJ obtains guilty plea from a military contractor for rigging bids on government military contracts.

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Compliance Kitchen

Compliance Kitchen on OFAC and DOJ Developments

The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman looks at OFAC issues Russia-related sanctions licenses and allows for limited marine activities on SDN vessels; DOJ obtains a guilty plea for EAR violations due to unlicensed exports of chemicals to a Chinese SOE listed on the Entity List.

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Compliance Kitchen

Blocking Russian Banks


The Kitchen looks at Department of Treasury sanctions which are now fully blocking Russia’s largest banks and banning new investment.

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Compliance Kitchen

OFAC Tech Company Sanctions


The Kitchen looks at new levied OFAC sanctions against Russian tech companies.