We have been working with a number of high profile financial services clients to review their approach towards sanctions compliance, specifically the regulations from the Office of Foreign Asset Control (OFAC) in the US, as well as other bodies such as the EU and UN who also issue prohibition notices.
As a bank or security and investment firm processing transactions denominated in or involving US currency, you might have an exposure of non-compliance with OFAC. OFAC sanctions also apply to insurance companies when claims involve a sanctioned country or sanctioned individual. 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