Tagged: screening

OFAC Enforcement Action: Double Check Your Screening Tools

Jessica Sanderson, Partner at the Volkov Law Group, re-joins us for a posting on a recent OFAC enforcement action. Jessica can be reached at [email protected] Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC did not impose any civil monetary penalties,...

OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions

Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front.  Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions program against Russia.  On its face this effort is more than Herculean, given the need to coordinate with the EU, Allies and partners.  It has been truly unprecedented and OFAC’s performance has...

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of this effort was to implement robust due diligence programs to screen and identify potential risks created by third party intermediaries. Hui Chen, DOJ Compliance Counsel, called 2015 “The Year of Due Diligence.” Many...