QUESTIONS AND CORRECT ANSWERS
◉ How many types of Sanctions evasion? Answer: Evasion can happen
in two ways. External evasion & Internal
External evasion happens when the customer or its third party violates
sanctions.
Internal evasion happens when an organization's own staff members
commit a violation, such as stripping.
◉ What is Stripping? Answer: Stripping is the intentional removal or
modification of information from a record, either by a customer or by an
organization's staff, to avoid detection against a sanctions list.
◉ What is External Stripping? Answer: External stripping happens when
a party outside the organization removes information from incoming
payment messages. This removal is a deliberate attempt to hide the
identity of the sender, recipient, or jurisdiction from where a payment
originated.
◉ What is U-turn payments? Answer: Stripping is associated with U-
turn payments. A U-turn is a transaction performed by a bank in one
country for the benefit of a bank in another country. A bank or other
, institution from country "A" sends a transaction through a bank in
country "B" using an offshore bank.
◉ Which Sanctions are most often associated with U-turn payments?
Answer: By using a U-turn payment, it is possible for sanctions evaders
to defy the following:
• Targeted sanctions against specific countries
• Inclusion of various entities on the Specially Designated Nationals
(SDN) list in an effort to prevent terrorism
• Individuals named as SDNs.
◉ How U-turn payments evade the sanction targets? Answer: The
evader simply removes the relevant information from the payment
message or wire.
◉ What is the motivation behind striping? Answer: Other cases are not
based on patriotism, solidarity, or political beliefs. In these cases, a
person or entity may offer a bribe to persuade the bank employee to alter
or omit the relevant information. In some cases, the bribe and the bank
employee's personal beliefs may both play a role.
◉ What is the causes of the noncompliance? Answer: The root causes of
the noncompliance included:
• Inadequate policies to ensure proper reporting of suspicious activity