Bank of China Order Confirms U.S. Regulators Are Willing to Take a Tough Line On Sanctions Missteps

August 16, 2018
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

After conducting a supervisory examination of its compliance program, the Office of the Comptroller of the Currency (OCC) has issued a $12.5 million fine and a Consent Order requiring Bank of China’s New York Branch to fulfill certain requirements within 90 days, some very far-reaching.

The Order, imposed by the OCC in April 2018, not only details shortcomings found in the Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program of one of the world’s biggest lenders, but also enterprise-wide deficiencies in its Office of Foreign Assets Control (OFAC) compliance requirements.

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‘Sanctions Busting’: The Risks and Rewards to those Trying to Circumvent the System

June 15, 2018
By: Keith Preble and Dr. Bryan R. Early*

The main goal of imposing sanctions on a target country or entity has always been to disrupt the target’s commercial relationships and make it costlier for them to do business. Governments try to achieve this goal by imposing administrative and criminal penalties for individuals and entities that violate their sanctions.

Though these restrictions generally apply only to firms and citizens operating in the country imposing the sanctions, the United States has recently employed far more aggressive and wide-reaching methods in penalizing foreign firms.

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OFAC Enforcement Actions By the Numbers: What Makes a Penalty?

Cuba, Iran, Sudan Top the List of OFAC Actions; Recent Trend Suggests Voluntary Disclosure Could Mitigate Penalty Amount

November 7, 2017
By Anna Sayre, SanctionsAlert.com

The dread of an OFAC penalty is something that no institution or company wants to face. But the Iran and Cuba sanctions regimes are more frequently enforced than others. The amount of sanctions enforcement cases based on violations of these two programs dwarfs any others by a wide margin. And, once you find out that your company has made a sanctions misstep, and you tell OFAC about it, you may mitigate the penalty amount.Since 2013, the benefits of voluntary disclosure have begun to show as part of a downward trend. (more…)

OFAC Enforcement Actions By the Numbers: Who’s At Risk?

Recent Up Tick in Number of OFAC Enforcement Actions against IT/telecom, Offshore Services; California, New York and Texas Companies Most At Risk

October 20, 2017
By Anna Sayre, SanctionsAlert.com

Are you a business that thinks OFAC only takes action against New York-based financial institutions? Think again.

Since 2014, OFAC enforcement actions have significantly increased against non-financial institutions, particularly in IT/telecom and offshore services industries. Furthermore, in addition companies in New York, those in Texas, and especially California, remain highly at risk. (more…)

Indictment of Lebanese Businessman, Tajideen, Points to Bold Methods of Sanctions Enforcement by DoJ and May Trigger Compliance Headaches for Banks

July 14, 2017
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

On March 24, 2017, Kassim Tajideen, an international financier and businessman operating a network of businesses in Lebanon and Africa, was charged by the U.S. Department of Justice (DoJ) with evading sanctions by purposefully concealing his association with certain companies, the profits of which were used in part to support the Shiite militant movement Hezbollah. This terrorist group was also designated by the U.S. Department of State as a Foreign Terrorist Organization in 1997. Tajideen, who was extradited from Morocco to the U.S., pleaded not guilty to all 11 counts. (more…)