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RESULTS FOR: OFAC

The Ransomware Payment Risk

January 27, 2021 | Cyber Security Risk + Compliance

Deciding whether or not to pay off a criminal that has crippled your organization’s operations with ransomware is a painful undertaking.  It is a crucial decision that must be made at a time often described as “pure chaos.” Management, attorneys, IT staff, incident response/digital forensics experts, the communications team, insurance companies and others all take part in addressing the crisis with an eye toward restoring operations to normal as quickly as possible.  Time is of the essence.  When technical recovery … Read More

Bank Secrecy Act Modernization Likely to Increase BSA/AML Enforcement, Including From Larger Whistleblowing Awards

January 13, 2021 | Financial Crime Consulting

2020 saw a substantial amount of enforcement activity in the BSA/AML/OFAC area.   Even prior to last month’s enactment of the Anti-Money Laundering Act of 2020 (the “2020 AMLA”), conventional wisdom favored an increase in enforcement activity by regulators and prosecutors for violations of laws in these areas under the incoming Biden Administration. [See Division F]

The 2020 AMLA just gave this area of enforcement a significant shot in the arm.  In an era where federal legislation has become … Read More

As Regulators Continue to Provide Guidance During These Unprecedented Times, Some is Easier to Interpret Than Others – A Focus on OFAC

May 6, 2020 | Compliance

Various regulators have recognized in guidance, press releases, and the like, that financial institutions and other corporations may need to adjust some or all of their compliance operations to handle the challenges posed by the COVID-19 pandemic.  Some guidance is easier to interpret and adhere to than others.  Examination timing and logistics continue to be adjusted on a case by case basis and firms have been working directly with their primary regulators to make appropriate adjustments as needed.  Some guidance … Read More

Combating Money Laundering and Terrorist Financing in the Art Community

April 7, 2020 | Compliance

Although perhaps not as brazen as the recent theft of a Van Gogh from a museum in the Netherlands, fine art can be an attractive target for accused money launderers like Nazem Said Ahmad. Mr. Ahmad was recently named a “designated person” by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC). OFAC pointed to the use of a Beirut art gallery by Ahmad to launder money in support of Hizballah (a/k/a Hezbollah) just as it issued … Read More

Sanctions Compliance Requires More Than a Filter

December 7, 2017 | Compliance Risk + Compliance

As we detailed in our last post, sanctions compliance is becoming increasingly difficult because the amount of data companies ingest is increasing, and because both OFAC and prominent regulators such as the New York State Department of Financial Services and the Monetary Authority of Singapore (MAS) have clearly articulated that simply screening transactions is not sufficient.

The sanctions program that addresses the threat of North Korea, or the Democratic People’s Republic of Korea, effectively highlights the regulators’ expectations. … Read More

Sanctions in 2017: Where are we now

November 30, 2017 | Compliance Risk + Compliance

As we approach the one-year anniversary of the Trump Administration, it is important to take stock of what has changed within OFAC regulations. This past year has seen several major changes to sanctions regulations, including the removal of most sanctions against Sudan (except for some list based programs), rollback of certain travel authorizations under the Cuban sanctions program, and a much-increased focus on North Korea and Venezuela.

In many respects, OFAC has not significantly changed their pace of designations, … Read More