In an article published in the May/June 2017 issue of ABA Bank Compliance (a publication of the American Bankers Association), Bass, Berry & Sims attorney Thad McBride provided insight on how banks can mitigate violations with the Office of Foreign Assets Control (OFAC). In January 2017, OFAC announced a settlement in which a large Canadian bank agreed to pay more than $500,000 in monetary penalties for 170 alleged violations of U.S. sanctions against Iran and Cuba. This especially costly example of financial stakes for banks and other financial institutions illustrates the importance of compliance, despite the challenges they face as they process millions of transactions on a daily basis and across international boundaries. While all risks cannot be eliminated, through careful investigation, compliance enhancements, monitoring and record keeping, financial institutions can help mitigate most risks.
For more details on key strategies to protect against violations and to remediate them when they do occur, access the PDF of the article, "Mitigating Economic Sanctions Risk," below.