Recently, the United Nations removed Dr. Kisoni Kambale from its Congolese sanctions list, which prompted the HM Treasury List in the UK to do the same. Dr. Kambale, a gold trader and owner of Butembo Airlines and Congocom Trading House, was on the list due to his financing of Congolese militias through his gold trading activities. He was removed from these lists due to his death last July.

OFAC, however, did not remove Dr. Kambale from its list. The purpose of the sanctions OFAC enforces is to prevent the transfer of assets to and from embargoed people and enterprises so they cannot be used for nefarious means. The key point with this example is that the deceased still have property; only by keeping their names on the Specially Designated Nationals (SDN) List can OFAC keep track of and prevent their assets from ending up in the hands of like-minded persons and enterprises. In theory, Dr. Kambale’s estate could be passed along to his former associates who may have interest in financing the same militia groups. Screening for him, even though he's deceased, would halt any such transactions. Any company taking a risk-based approach to screening that skews to the side of less risk—even those not specifically bound by OFAC sanctions—would be wise to adopt such a practice.

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While "euro" is in its title, that doesn't mean that SEPA only needs to be considered by those who use that as their main currency. According to a recent article in Securities Industry News many U.S. banks are struggling with the requirements of this European-focused directive.

Supplying all of the component parts of a SEPA-compliant payment instruction—the IBAN, the connected SWIFT/BIC, etc.—is presenting itself as a stumbling block for sending payments into the eurozone. Many were not prepared with such information while others have been surprised by the fees levied by the receiving banks when it wasn’t supplied. There are distinct guidelines for what must be supplied in a SEPA-compliant payment instruction as well as accurate, reliable resources for obtaining the necessary information. U.S.-based banks need to educate themselves and realize that this regulation will apply to them when working with European-based banks. While an ad-hoc look-up application might suffice for those with low payment volumes to the region, a data file containing IBAN information is the best option for those institutions that have regular dealings with SEPA countries and territories. Investing up front by learning the rules and taking the time to search out the needed payment information will save time and money in the long run by reducing returned items and repair fees.