November 4, 2019 By: Thomas Nollner*
A commonly held misconception within the sanctions industry is that Office of Foreign Assets Control (OFAC) sanctions programs only apply to financial institutions. Recent large civil liability settlements between OFAC and several large banking companies support this misconception. As published in the international press, Standard Chartered Bank reached a settlement agreement with OFAC in April 2019 for an apparent violation by paying OFAC $639 million; Societé Génerale S.A. in November 2018 reached a settlement agreement for the same type of apparent violation by paying OFAC $53 million; and J.P. Morgan Chase in October 2018 paid $5 million to OFAC for an apparent violation.
June 21, 2019 By: Natasha Bright, Reporter ACSS
Compliance with sanctions isn’t just a bank issue. In the past year, the Office of Foreign Assets Control has begun to focus on industries outside the financial sector including those involved in shipping. Sanctions related to Iran, North Korea and Venezuela have increased pressure on maritime trade businesses including shipping companies, insurance companies, commodities traders, associated financial institutions, and others. In response, organizations are looking for guidance and solutions to adapt to the rapidly evolving and complex compliance landscape
May 30, 2019 By: Glenda Juliano, CAMS
Restrictions apply to entities owned 50 percent or more, individually or in aggregate by one or more persons on the SDN or SSI List.
May 17, 2019 By: Anna Sayre, Head of Legal Content, ACSS
On May 2, 2019, following an official announcement by Under Secretary of the Treasury for Terrorism and Financial Intelligence during the American Bankers Association/American Bar Association Conference on December 3, the Office of Foreign Assets Control (OFAC)released its much-anticipated Framework for OFAC Compliance Commitments delineating the key elements that it considers to be essential to an effective sanctions compliance program (SCP).
May 2, 2019 By: Anna Sayre, Head of Legal Content, ACSS
Regulators at the U.S. Treasury have signalled their top priorities for the year, and it doesn’t look good for sanctions violators. The Treasury’s Office of Terrorism and Financial Intelligence (TFI)’s new budget proposal calls for a substantial increase in funds to both fight terror and enhance sanctions policy enforcement.
April 23, 2019 By: Scott Nance*, Principal, LC Consulting
Recent times have seen an uptick in sanctions enforcement actions, placing an onus on many compliance suites and officers to take head and build a robust sanctions compliance program.