Amman, Jordan

In an effort to enhance the Jordanian banking sector’s capacity to meet growing global regulatory challenges, the Association of Banks in Jordan, in collaboration with the international law firm Eversheds Sutherland, organized a specialized training workshop titled:
“Scenario-Based Training on National Security and Regulatory Risk in Financial Institutions”

The workshop was held at the Association’s headquarters on Monday, June 30, 2025, and witnessed a strong turnout from compliance officers, risk managers, legal advisors, and specialists in sanctions and anti-money laundering (AML) from member banks.

The workshop aimed to equip participants with the necessary tools to understand and implement effective, real-time responses to events related to national security. It focused on realistic simulations of national security scenarios that global financial institutions may face, introducing participants to the real-world pressures they could encounter.

A specialized team of partners from Eversheds Sutherland conducted the workshop, which lasted for three hours and covered several core topics, including:

• S. Government Enforcement Priorities and American Horizon Scan: Focused on current geopolitical challenges such as Syria, Iran, China, and tariffs, and their impact on financial institutions. The session emphasized that AML enforcement is a national security priority.
• Compliance Initiatives from U.S. Agencies: Covered initiatives from the U.S. Department of Justice (DOJ), Department of the Treasury, and Department of Commerce, highlighting KYCC (Know Your Customer’s Customer) efforts and the U.S. administration’s February 4, 2025 directive to the Treasury to consider imposing KYC/KYCC obligations on Iran-related transactions, which may have far-reaching consequences for financial institutions.
• Corporate Whistleblower Rewards Program: The DOJ launched a three-year pilot program in August 2024 offering financial rewards for reporting certain types of corporate misconduct. This includes criminal violations by financial institutions and their employees, foreign corruption, domestic bribery, sanctions violations, terrorism financing, and customs, trade, or procurement fraud.
• Developments in U.S. Sanctions: Discussed potential shifts in sanction enforcement priorities in line with current administration goals. Topics included sanctions enforcement and export control priorities, especially Executive Order 14165 issued on January 25, 2025, which established a process for designating certain international criminal cartels as Foreign Terrorist Organizations (FTOs) or State Sponsors of Terrorism (SSTs).
• Diversion Risk: Highlighted frustration among U.S./EU law enforcement agencies over the ineffectiveness of sanctions/export controls on Iran in light of diversion activities related to Russia.
• Practical and Interactive Scenarios: The workshop presented several complex scenarios involving national security challenges faced by non-U.S. banks engaged in U.S. dollar transactions, aiming to identify issues and evaluate possible responses.
• Updates on Syria: It was noted that on May 23, 2025, the U.S. Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25) for Syria, providing immediate sanctions relief in line with a Presidential announcement. The license aims to help rebuild Syria’s economy, financial sector, and infrastructure, and allows for new private investment and private-sector activity.

During the opening of the workshop, Dr. Maher Al-Mahrouq, Director General of the Association of Banks, emphasized the timely nature of the event, noting that the regional and global banking environment is undergoing increasingly complex and rapid transformations, especially concerning compliance and national security risks.

Dr. Al-Mahrouq added that it has become clear that financial institutions no longer merely serve as providers of financial services—they are now at the heart of the global national security and governance system. He stressed that banks today are expected to serve as the first line of defense against money laundering, terrorism financing, and sanctions evasion, and to comply with a constantly evolving web of regulations issued by multiple authorities across various jurisdictions.