Russian ‘Mirror Trading’ Case Reveals Five Long-Running Compliance Failures at Deutsche Bank

March 9, 2017
By: Anna Sayre, Legal Content Writer,

On January 30, 2017, the New York State Department of Financial Services (DFS), NY’s financial watchdog, as well as the Financial Conduct Authority (FCA), financial services regulator in the UK,ordered Deutsche Bank to pay $425 million and £163 million, respectively, for violations of anti-money laundering regulations and continual, wide spread compliance failures. The so-called ‘mirror trading” scheme, involving the German lender’s Moscow, London and New York offices,resulted in $10 billion being transferred out of Russia. (more…)

The Increasing Importance of Sanctions Compliance and How To Stay One Step Ahead on Your OFAC Examinations

February 15, 2017
By: Anna Sayre, Legal Content Writer,

Today, staying compliant with the continually changing breadth of sanctions regulations and laws is no easy task. Sanctions, regulated, among other agencies, by the U.S. Treasury’s Office of Foreign Assets Control (OFAC), continue to pose an increasing risk in terms of number and complexity.Though it is now quite common for a financial institution to have a Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program, compliance professionals are recognizing the growing need for an OFAC risk assessment and compliance program as well. In a recent poll conducted by Sanctions Alert, when attendees were asked if the OFAC portion of the BSA/AML examination conducted by federal bank regulators was more important, less important or the same as compared to 5 years ago, a whopping 75% said that the OFAC portion of the assessment had become more important. (more…)

The SEC’s Office of Global Security Risk adds an extra layer of teeth against sanctions violations

Date: September 1, 2016
By: Anna Sayre, Legal Content Writer,

 The global risk environment has changed dramatically in recent times, and continues to change almost daily as we learn of new or possible global threats of terrorist activity. The regulator of the securities industry, the US Securities and Exchange Commission (SEC) plays an important role to protect against a possible terrorist attack. The SEC’s Office of Global Security Risk (OGSR), in operation since 2005, provides an extra layer of protection against such risks by monitoring disclosures related to business activities involving US sanctioned countries, as well as prompting further information regarding those disclosures (or lack thereof) from companies in the US and abroad.


Reviews by bank examiners may result in action by OFAC

Date: August 17, 2016

 The US Treasury Department’s Office of Foreign Assets Control (OFAC) plays, arguably, the biggest role in implementation and enforcement of US sanctions. All US persons, including US financial institutions, must comply with OFAC regulations. Despite this fact, OFAC does not specifically require that financial institutions set up policies or programs to ensure compliance with sanctions laws. OFAC simply requires that financial institutions do not break the laws that it administers. Nevertheless, the potential consequences of not having a comprehensive sanctions compliance policy should not be taken lightly. (more…)