Insights

January 10, 2023 | Financial Crime Consulting National Security Risk + Compliance

As the Russia – Ukraine war rages on, one outcome so far is clear:  the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against Russia since February 2022 combined with their limited military support, demonstrate that the West’s tight, global coordination helps Ukraine courageously defend its nation and citizens. Importantly, coordinated alignment also protects the homeland and critical infrastructure of each Western nation, including that of the United States.… Read More

April 10, 2022 | Compliance National Security Risk + Compliance

With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international agencies’ intent on strict compliance. It is increasingly necessary to regularly evaluate supply chain and trade operations to ensure companies are meeting their compliance expectations.  

For one, sanctions compliance is more than payments filtering and screening. It is also about export controls and licensing, cryptocurrency, and other … Read More

February 28, 2022 | Compliance Uncategorized

How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did not sufficiently invest in the right people, processes, and/or technologies to filter, freeze, and report targeted assets?

As we witness the Russian military assault in (and tremendous courage of) Ukraine, and its citizens, the West is responding with major financial sanctions to freeze assets … Read More

October 14, 2021 | Financial Crime Consulting test

The regulatory landscape for fintechs is continually evolving. It is critical that compliance officers stay on top of what is going on in the industry to ensure they make the best decisions and take proactive measures in alignment with current regulations. The recent OFAC settlement with Payoneer, Inc. for apparent violations of multiple sanctions programs is an excellent case study for compliance officers with fintechs and payment processors to heed when enhancing their compliance programs.

For those not familiar with … Read More

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

November 11, 2020 | Compliance Financial Crime Consulting

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 Financial Crime Consulting

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.

This latest enforcement action against DB follows several others issued against the bank by NYDFS since 2015, including for improper conduct arising … Read More

December 7, 2017 | Compliance National Security 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

November 30, 2017 | Compliance National Security 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