On June 29, 2017, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued for public inspection a notice of proposed rulemaking (the “Proposed Rule”) that would restrict a Chinese commercial bank’s access to the US financial system based on a finding that the bank was involved in money laundering activities involving North Korea. This action coincided […]

On June 6, 2016, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) released its 24th annual Terrorist Assets Report (TAR), an update to Congress detailing the amounts of assets in relation to international terrorist organizations or state sponsors of terrorism that have been frozen up until December 31, 2015. https://www.treasury.gov/resource-center/sanctions/Programs/Documents/tar2015.pdf The […]

If any business thinks getting caught evading a sanctions program of the US Office of Foreign Assets Control (OFAC) is inconsequential in money and reputation, they should look closely at the settlement agreements OFAC signs with each penalized business. Like clockwork, at a rate of 5.9 cases per month from April 4, 2003 to February […]

A 50% narrative sanctions applies to an entity not sanctioned by name or appearing on a blocked / restricted entity list but is covered by a narrative statement on a sanctions program extending such sanctions to such non-listed entity. Firms face the challenge of understanding to what extent they should screen their customers and key […]

False Hit Lists Guidance U.S. persons are responsible for developing appropriate risk-based controls to enable compliance with the regulations administered by the Office of Foreign Assets Control (OFAC). Sanctions related screening is often a valuable tool in enhancing compliance controls. U.S. persons, including financial institutions, frequently conduct sanctions screening of customer databases and/or transactions (e.g., […]

Financial institutions and other U.S. persons who conduct business with foreign parties have become increasingly aware of their obligation to thoroughly vet the parties with which they are doing business. Often, as part of their due diligence process, employees are tasked with screening the Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals […]

The Treasury’s Office of Foreign Assets Control said the bank had handled 222 US securities transactions worth $2.5 million between 2008 and 2013 on behalf of an individual client who was blacklisted by OFAC under US sanctions. The client was not identified by the Treasury, but it said the transactions benefited a person or group […]

PayPal has agreed to pay $7.7 million to settle charges that it violated numerous sanctions programs against countries that include Iran, Cuba and Sudan, according to the U.S. Treasury Department. For several years up to and including 2013, PayPal is accused of failing to employ adequate screening technology and procedures to identify the potential involvement of […]