SIA Submits Comments to the US Department of the Treasury on the Designation of Nauru and Ukraine
The Securities Industry Association (SIA)* provides comments to the U.S. Department of the Treasury (Treasury)on a Notice of Designation of Nauru and Ukraine as primary money laundering concerns. SIA believes that the Ukraine Special Measures either should not be adopted or should be replaced with appropriate sanctions against Ukraine. SIA also believes that without adequate specificity within the Final Special Measures, institutions could be at substantial risk in their attempts to implement the Final Special Measures. There should be a delayed effective date for the Final Special Measures so that institutions have sufficient time for implementation. SIA requests that Treasury give institutions more flexibility in complying with the Special Measures during the initial period.
*SIFMA is the product of a merger between the Securities Industry Association and The Bond Market Association (TBMA) in 2006.