The US Government Increases Pressure on Industry to “Know-Your-Customers” and “Know-Your-Suppliers” While Separately Acknowledging This Is Difficult

On November 25, 2019, the United States both issued an enforcement action against a private company for, in part, failing to identify a prohibited counterparty in a commercial transaction and at the same time acknowledged—in a government accountability report—the difficulties that government agencies themselves are facing in precisely the same area.