fis risc solutions · a return to the era of genghis khan & the “golden horde” after the...
TRANSCRIPT
FIS Risk, Information Security and
Compliance (RISC) Solutions
Crimea Sanctions Compliance
Challenges and Solutions
www.fisglobal.com/RISC
May 16, 2017
Robert A. Marro, Jr.
Director, AML & Sanctions Compliance
FIS RISC Financial Crime Advisory Services
Crimea Sanctions Background
• In February 2014, Russian
Federation military troops led by
special operations forces (Spetsnaz)
invaded the Crimea region of Ukraine
and facilitated the annexation of the
Crimean Peninsula by Russia
• In response, President Obama
signed four executive orders
imposing sanctions
• Specifically, Executive Order 13685,
Blocking Property of Certain Persons
and Prohibiting Certain Transactions
with Respect to the Crimea Region of
Ukraine, imposes general prohibition
on certain transactions with all
persons and entities located in
Crimea.
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Crimea Sanctions Challenges
• E. O. 13685 targets a ‘geographical region,’ which is not
a country; it is a disputed area between two countries,
Russia and Ukraine
• The net effect of discontinuing any or all trade
relationships with Russia and Ukraine so as to comply
with OFAC policy would provide highly problematic ‘ripple
effects’ on global politics and economy
• Residents of Crimea consider themselves living in Russia
or Ukraine, depending on their individual political
allegiance
• Addresses in Crimea will not necessarily have the word
“Crimea” in them, yet will still be legally
functional/acceptable, so the single key word check
would not be effective for compliance with E. O. 13685.
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Crimea Sanctions Challenges (continued)
• Names of municipalities in Crimea may be spelled in the Latin
alphabet using transcription from Russian or Ukrainian
language, yielding to different spellings of the localities in
English
• Both Russia and Ukraine are undertaking steps to restore the
historic “Golden Horde” Tatar names of Crimean municipalities;
these names can then be legally used
• Most public sources, such as Google, provide different spellings
of Ukrainian names for the municipalities than those a native
Ukrainian-speaker would use
• Very limited volume of information regarding Crimea and
currently accepted legal names of its geographic locations is
available in languages other than Russian or Ukrainian.
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A Return to the Era of Genghis Khan & the “Golden Horde”
The Golden Horde was the western part of Genghis Khan’s Mongol Empire, 1239 AD
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A Return to the Era of Genghis Khan & the “Golden Horde”
After the Mongol Empire broke up in 1259, the Horde was a functional polity
speaking Mongol Tatar. The Khanate of Crimea was the longest existing part of
the Golden Horde until Catherine the Great annexed it in 1783. This is a scene
from the 1938 Sergei Eisenstein film “Alexander Nevsky” of the Mongol Horde
Khan inviting Russian Prince Alexander to join the Golden Horde, circa 1250 A.D.
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Crimea Sanctions Challenges
A Return to the Era of Genghis Khan and the Golden Horde
Historic Name Convention Example 1 - SEVASTOPOL
• Russian translation - Sevastopol
• Ukrainian translation - Sebastopol
• Crimean Tatar: Aqyar (historic Golden Horde name)
Historic Name Convention Example 2 - SIMFEROPOL
• Russian translation - Simferopol
• Ukrainian translation - Simferopol
• Crimean Tatar: Aqmescit (historic Golden Horde name)
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Crimea Sanctions Compliance Solution
• FIS-RISC has employs professionals qualified both in
Sanctions compliance and in foreign languages to review the
information in both Russian and Ukrainian languages and
derive possible names of municipalities that can serve as
addresses in Crimea.
• We have compiled a full list of over 1,900 municipalities in
OFAC-sanctioned Crimea region, each with two or three
(depending on the status of governmental approval of the
“historic name”) different spellings in English.
• FIS-RISC is monitoring for regulatory changes in
Russia/Ukraine and updates the list as the new names are
approved
• This solution is being offered as a Special List within Prime
software, or as a separate, stand-alone list with ongoing
support
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