Guidance
December 26, 2019

Sanctioned Actors Offer Mobile Apps

By Samuel Rubenfeld

Sanctioned entities, or businesses with connections to designated parties, offer apps available for download in the app stores of major technology providers, Kharon found.

The apps represent media, banking, mobile payments, travel and hotels. They span the globe and are associated with parties sanctioned under various U.S. authorities. Many are the mobile versions of news organizations connected to designated parties, according to a review of the Apple App Store and the Google Play store. 

A review of the available apps follows a U.S. Treasury Department settlement last month with Apple. The company’s sanctions screening tool allowed SIS d.o.o, a since-dissolved, delisted front for a sanctioned Slovenian steroid trafficker, to host software applications and associated content on the App Store for at least two years, the Treasury said. The apps found by Kharon may show further screening deficiencies on the part of the mobile firms. 

“Screening programs need to be robust and multi-faceted,” said Douglas Jacobson, a partner at the international-trade focused law firm Jacobson Burton Kelley PLLC, in a message to Kharon. “Compliance programs must be able to screen all parties to a transaction, including owners, beneficiaries, banks, and software should have the ability to flag names of all types.”

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