A friend sent this to me Who knows if it has any substance. Interesting background of the author -- check it out.
FROM A DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
More about the Author
Alert for large wire transfers in advance of sanctions
19 May 2008
Reliable sources have indicated that President Bush will announce some types of sanctions against Venezuela on Wednesday. It is not known whether this will involve OFAC listing of financial institutions and their owners, US visa revocations, the designation of certain Venezuelan entities and individuals, or the naming of government-controlled companies. Whatever does occur could seriously disrupt the ability of the named designees to conduct financial transactions, as they will be thereafter denied access to the US financial structure. They may also have US-based funds and assets frozen by Treasury.
Assuming arguendo that this information is also known to some of the suspect financial institutions, corrupt PEPs, and individuals most likely to be named, compliance officers should alert their staff to maintain a high level of vigilance for large funds transfers being requested for transfer outside the US, and into offshore financial centres, whether located in the Caribbean, or in Western Europe.
US Regulators may take a dim view of the fact that a freeze order was served upon your bank, only to learn that you approved the transfer, hours earlier, of the money, into a known tax haven jurisdiction. It might make the agency involved decide to take a hard look at your compliance policies and procedures, including a "look-back" of a couple of years. Since your institution may not have properly vetted the Source of Funds for the since-departed cash, you might have a problem.
Ensure that any large funds transfer request that seems to be outside the normal course of business, and involving known Venezuelan nationals, or companies in which they have an interest, gets a good look.
http://www.world-check.com/articles/2008/05/19/alert-large-wire-transfers-advance-sanctions/