The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department has long administered and enforced economic and trade sanctions against foreign countries, regimes, terrorists, international narcotics traffickers, and transnational organized crime. However, OFAC compliance has increased in complexity and clarity with guidance released within the past few years. The civil monetary penalties and reputational risk are strong reasons why financial institutions need to employ seasoned sanctions officers and automated scanning solutions.
One recent case study garnered worldwide attention in the compliance industry, with lessons learned on what NOT to do in a sanctions program. On September 9, 2020 Deutsche Bank Trust Company Americas (DBTCA) agreed to pay two civil monetary penalties – one for $157,500 and the other for $425,600 – to the Department of the Treasury OFAC for violations of the Ukraine-Related Sanctions Regulations. What can AML professionals learn from the DBTCA case?