In recent years，the trade finance community has seen a surge of policy formulation or subsequent revision on global sanctions and Anti Money Laundering (AML). It is necessary that banks follow the trends and adopt their own risk-based approaches to have relative compliance risks in control. The following is a summary of important relevant guidance papers published in recent years. This includes some key changes made this year.

Highlights of OFAC Policies in 2019

On August 5，2019，President Trump issued Executive Order 13884 blocking all property of the government of Venezuela，a striking escalation of sanctions against the regime of President Nicolas Maduro. Statements issued by the White House and the State Department pointed out that this escalation was meant to target the Maduro regime for its continued abuses of human rights and repression. According to a Q&A from the Office of Foreign Assets Control (OFAC)，US persons without authorization from OFAC are generally prohibited from engaging in transactions with the government of Venezuela，or persons in which the government of Venezuela owns，directly or indirectly，a 50%  or greater interest. Financial institutions are expected to conduct due diligence on their own direct customers (including，for example，their ownership structure) to confirm that those customers are not persons whose property and interests in property are blocked. OFAC has issued 29 valid general licenses authorizing some transactions. Banks should make crystal clear what is prohibited and what is permitted in related transactions.

Sanction Risks in Civil Aviation