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New and changing OFAC sanction programs and compliance requirements continue to pose increased challenges for all compliance officers. Tim's presentation will address best practices for updating and testing your OFAC program in this fast-changing compliance arena, and how to address the hot spots that hold the greatest risk for regulatory criticism and OFAC violations for financial institutions of all sizes.
This fast-paced 2-hour webinar will provide both the new compliance professional and the seasoned OFAC practitioner with the most current information on OFAC compliance issues. Beginning with a brief foundation on sanction compliance fundamentals and then ramp up quickly to explain in detail specifically what has changed in the OFAC Sanctions arena (Russian, Chinese and Virtual Currency challenges) and how these changes can impact your institution’s OFAC program.
Tim will outline and clarify the significance, complexities, and consequences of the Global Financial Sanctions Regime against Russia for its invasion of Ukraine.
The presentation is focused on assisting Anti-Financial Crime Compliance Practitioners in assessing the impact of these sanctions on their institution’s sanction compliance programs. by:
- Understanding these sanction changes
- Knowing the important components of OFAC sanctions in general
- Knowing how to stay current when sanctions change
- Augmenting and testing your vendors actions
- How to assess new sanctions risk factors from your institution’s perspective:
- client risk, geographic risk, transactional risk, operational/technology risk, and regulatory (examiner) risk -
- Communicating any identified increased risk to your leadership team
- Positioning for the potential need for more resources (FTEs, intelligence, or technologies).
- Crafting risk appetite statements based on historical findings that are specifically designed to reduce consulting and examiner risk
- Training and educating your institutions staff and leadership
- Testing your interdiction filters
- Request White Papers from your vendors on system functionality and settings
The presentation will provide a quick overview on what you need to understand about Russian sanctions from 2014. It will also look at subsequently applied sanctions including: CAATSA, E.O. 13849, PEESA, E.O. 14039, which also targeted Russian related activities. CAAPTA will be explained, and the advent of secondary sanctions will be discussed.
The presentation will also review details of OFAC’s recent Russian designations, explaining the utilization of the new Directives to recognize what should be blocked and what should be rejected. Next is a review of the nature of the early General Licenses and the impact of their “wind down periods” and divesting deadlines.
Time will also discuss:
- Due-Diligence on Ukrainian NGOs
- How the Russians are evading sanctions - what we know and what we suspect.
- Expectations for Russia-related sanctions as Russian aggression evolves
- Using recent OFAC and FinCEN guidance documents
- Tips for addressing the due diligence challenges of Chinese sanctions and “hits” on the Russian SSA List
- Fundamentals of compliance with Iranian Venezuelan, North Korean, and Cuban programs
The presentation will include specific tips for addressing the due diligence challenges of Chinese sanctions and for addressing "Hits" on the Russian SSI List (E.O. 13622), as well as the specific fundamentals for being in compliance with the sanctions programs in the Iranian, Venezuelan, North Korean, and Cuban programs. Tim will provide detailed explanations of industry best practices and hands-on tips for reassessing all areas of your institution's OFAC compliance program.
From exam prep best practices to what you need to know and what you don’t need to know about the 4 new OFAC sanction programs in order to have ; CAPTA, CAR, Hong Kong and ICCP. As well as what’s New:
The Venezuelan, Sectorial Sanction Identification List (SSI) is far more complex than any previous OFAC programs. The handling of Venezuelan, SSI matches requires extensive due diligence on the specific details related to the payments and accounts that are involved (Screening is the easy part of this process). State Department and Treasury officials are talking about increasing the use of these new complex sanctions programs. This is the new generation of sanctions- "Smart Sanctions." By all indications, sanctions program requirements will continue to be even more arduous.
OFAC's programs are more exacting, its influence is greater, penalties are higher and its reach continues to grow wider.
Tim is an enthusiastic proponent of risk based BSA & OFAC regulatory compliance and understands that a knowledgeable risk-based program can be both efficient and economical. The key is to thoroughly understand all the factors that affect each OFAC risk exposure and how each of these dynamics impact the IT environment and monitoring burdens of the OFAC compliance professional.
- Understand why OFAC compliance is so challenging
- Understand how to communicate risk-based OFAC policies and monitoring practices to your examiner
- Understand the factors that influence and reduce your institution's inherent OFAC risk
- Understand regulatory risk and the risk of an actual OFAC violation and the difference between the two.
- Why OFAC's sanctions are becoming a more important element in BSA exams
Considering all the new developments in the OFAC compliance arena, it's easy for something to slip through the cracks. This program will help provide the peace of mind you need by knowing you are one step ahead and prepared for anticipated changes within your next BSA-OFAC exam.
Questions and Answers
This was very timely and informative. Appreciate Tim trying to break some of these sanctions down for more understanding.
This was very timely and informative. Appreciate Tim trying to break some of these sanctions down for more understanding.Read Less