OFAC Sanctions
Challenges faced by private banks in complying with sanctions from the US Treasury‘s Office of Foreign Asset Control (OFAC) are significant in current market conditions. We have been working with various high profile FS clients to review their approach and help them with:
- Development of a model to identify, measure and report risks associated with OFAC.
- Management of conflicts between a report to OFAC and abiding by local banking secrecy and data protection laws.
- Construction and conduction of a review process.
- Using our data analysis skills with tools such as SQL and ACL to identify transactions that may be in non-compliance of OFAC requirements.
As a private bank having transactions involving US currency, checks, wire transfers and letters of credit, you might have a significant exposure of non-compliance with OFAC. Violations could lead to criminal prosecution with penalties ranging up to 10 years in prison and $1 million in corporate fines and $100'000 in individual fines, per incident. In addition, civil penalties can be assessed up to $250'000 per violation.
Our experts help you in reviewing your strategy and policy. We implement methodologies to comply with sanctions regulations, screen systems & transactions to identify those at risk and offer investigative services in order to establish the scale and root cause of non-compliance. We support staff awareness and technical trainings.
Useful links
Key contacts
© 2013 Deloitte AG. All rights reserved. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity.
Please see About Deloitte for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its Member Firms.