Earlier this year the Treasury Department’s Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. It describes essential components of a sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, and training).… Continue Reading
Boards of directors at financial institutions play a crucial role in the adoption and implementation of effective enterprise-wide Anti-Money Laundering (AML) and sanctions compliance programs.
It’s up to them and senior management to set the strategy, ensure there are adequate resources, and empower leaders to promote an effective AML compliance program and monitor the organization’s risk profile.… Continue Reading
Zurich-based UBS AG agreed to pay just over $1.7 million to resolve civil allegations that it processed 222 transactions for a client that apparently violated U.S. anti-terrorism sanctions.
“Multiple business lines and personnel within UBS, including supervisory and management staff within the bank’s compliance department, had actual knowledge of the conduct that led to the apparent violations,” the U.S.… Continue Reading
Last week, the UK’s Fianncial Conduct Authority published thematic financial crime risk reviews into 21 small banks and ten commercial insurance intermediaries. It also commenced a consultation exercise on its proposed guidance on financial crime systems and controls.… Continue Reading
Law-related employment for grads from American law schools isn’t exactly robust. In 2013, the ABA Journal said, only 57 percent of the that year’s JDs had full-time bar-passage-required jobs.… Continue Reading