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  • Treasury supports resolution establishing humanitarian carveout across UN sanctions regimes

    Financial Crimes

    On December 9, Secretary of the Treasury Janet L. Yellen issued a statement on the adoption of United Nations Security Council Resolution 2664, which establishes a standardized humanitarian carveout across UN sanctions regimes. Yellen explained that while sanctions are an important tool for globally combating key threats such as money laundering and terrorist financing, Treasury also recognized the potential for unintended consequences and strongly recommended streamlining humanitarian authorizations across sanctions programs. Resolution 2664 “further enables the flow of legitimate humanitarian assistance supporting the basic human needs of vulnerable populations while continuing to deny resources to malicious actors,” Yellen said.

    Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury OFAC Sanctions OFAC Designations U.N.

  • States launch investigation into banks’ ESG investing and banking

    State Issues

    On October 19, a coalition of 19 state attorneys general, led by Missouri, Arizona, Kentucky, and Texas, announced that six large U.S. banks were served civil investigative demands (CIDs) asking for information related to their involvement with the U.N.’s Net-Zero Banking Alliance (NZBA). The Missouri AG’s office, which has led the opposition against ESG (environmental, social, governance) investing and banking practices, stated that NZBA-member banks are required to set emissions reduction targets in their lending and investment portfolios to reach net zero by 2050. According to the Missouri AG, the NZBA serves to “starve companies engaged in fossil fuel-related activities of credit on national and international markets” by requiring banks to cede authority to the U.N. The CIDs seek information from the banks on topics related to, among other things, (i) their involvement in affiliated global climate initiatives; (ii) how NZBA and Principles for Responsible Banking objectives have been incorporated into their operations; and (iii) the extent to which the banks have fulfilled their “commitment to ‘facilitat[e] the necessary transition in the real economy through prioritizing client engagement and offering products and services to support clients’ transition,’” as well as their “commitment to ‘engag[e] on corporate and industry (financial and real economy) action, as well as public policies, to help support a net-zero transition of economic sectors in line with science and giving consideration to associated social impacts.’” 

    State Issues State Attorney General ESG U.N. CID

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