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As a seller, Alcon Labs would be the receiver of payment. Why did it get pursued by regulators going after originators of payment?
It was not an actual payment that violated the sanctions. It is against regulations to do business at all with blacklisted entities/countries. Alcon Labs could have avoided this by screening their customer and vendor databases against the blacklists.
Okay. Since you mentioned regulator going after originator of payment and gave Alcon Labs example "For a case in point", I thought Alcon was caught for originating payment to banned parties. With that out of the way, AFAIK, Iran and Sudan are both on US
export watch list. Do you really think Alcon Labs would need specific customer and vendor databases to know it was illegal to sell to *anyone* in those two countries?
Practically, you wouldn't think they would...but US regulations cover individuals/entities in many countries so to have a proper compliance process you would need to continually screen not only payments but also business partners no matter where they are.
Banks do not screen only payments going to sanctioned countries. They screen every cross border payments and oftentimes every domestic payment.
Head of Global Sales
26 Feb 2016