RESULTS FOR: Sanctions
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
November 11, 2020 | Compliance
In its recently issued Sanctions Systems Annual Report FY 2020, the World Bank Group (WBG) confirmed its commitment to investigate and sanction corruption and fraud occurring in bank-financed projects, despite the unprecedented challenges of the COVID-19 pandemic. The report, co-authored by the Integrity Vice Presidency (INT), the Office of Suspension and Debarment (OSD), and the Sanctions Board, revealed little coronavirus-related slowdown in the WBG’s enforcement activities. To the contrary, the bank’s in-house investigatory teams initiated roughly the same number of … Read More
July 9, 2020 | Compliance
The New York Department of Financial Services (“NYDFS”) recently sanctioned Deutsche Bank (“DB”) $150 million for BSA/AML deficiencies. According to the regulator’s factual findings, the compliance failures arose in connection with the bank’s private wealth relationship with Jeffrey Epstein, and correspondent banking relationships with Danske Bank Estonia (“Danske Estonia”) and FBME Bank (“FBME”), both located in Eastern Europe.
As the sanctions landscape becomes more complex and enforcement efforts expand across an array of federal agencies, it is increasingly necessary to regularly evaluate supply chain and trade operations to ensure companies are meeting their compliance expectations. The problem is compounded as the information technology landscape grows more robust and suppliers and buyers can be screened in real time, as well as the related parties within the transaction.
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.
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