OFAC Means Office of Foreign Assets Control

OFAC is an office within the Terrorism and Financial Intelligence Office at the US Department of the Treasury.

The Office of Foreign Assets Control (OFAC) is a financial intelligence and enforcement organization of the U.S. government charged with planning and execution of economic and trade sanctions in support of U.S. national security and foreign policy objectives. Acting under Presidential national emergency powers, OFAC carries out its activities against problematic foreign states, organizations and individuals alike. – Wikipedia

http://historiasbastardasextraordinarias.blogspot.com/2014/12/critica-cine-the-interview.html
Randall Park in The Interview via Historias Bastardas Extraordinarias

Historically, OFAC was dealing with sanctions on Iran, North Korea and Cuba, the usual suspects. But nowadays, OFAC also deals with individuals connected to Russian President Vladimir Putin and individual terrorists.

Making a career in this area of regulations involves great amount of interest in both financial crimes investigations and geopolitics. It also involves keeping up with information on what other regulatory bodies are doing, such as FinCEN, FINRA and Department of Homeland Security.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


FATF Means Financial Action Task Force

The Financial Action Task Force (FATF) is an inter-governmental body established in 1989 by the Ministers of its Member jurisdictions. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. The FATF is therefore a “policy-making body” which works to generate the necessary political will to bring about national legislative and regulatory reforms in these areas. – FATF

FATF is housed at the Organization Economic Co-operation and Development (OECD) in Paris, France. It works with the G-7 world leaders, G-20 finance ministers to make policy and enforcement recommendations regarding anti-money laundering, anti-bribery, anti-corruption, anti-terrorist financing and anti-piracy. It is part thinktank and part NGO.

FATF has a membership status for each country. There are thirty five member nations and the rest are either observing the guidelines and recommendations or not actively doing so. FATF also has a Blacklist, a list of banned nations. The usual suspects are listed: Iran, North Korea, etc.

The Treasury represents the United States at the FATF. The Financial Crimes Enforcement Network (FinCEN) is the primary contact for guidance.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


Managing Regulatory Risk

On Monday, January 26, Associations of Certified Anti-Money Laundering Specialists (hereon ACAMS) held its Third Annual AML Risk Management Conference at The Conrad Hotel in downtown New York. Over the course of this week, summaries and takeaways from the key notes and panel discussions will be shared in this blog.

  • John Byrne, Moderator, Former President of Condor Consulting LLC
  • Jamal El-Hindi, Associate Director, Policy Division, Financial Crimes Enforcement Network (FinCEN), US Department of the Treasury
  • Sarah Green, Senior Director, AML Compliance, Financial Industry Regulatory Authority (FINRA)
  • Denise Reilly, Managing Director, Global Head of BSA/AML Compliance, Citibank
  • James Vivenzio, Senior Counsel for BSA/AML, Office of the Comptroller of the Currency (OCC)

HeaderThis panel discussion covered topics ranging from expectations from regulators, culture of compliance in a firm, and personal liability. The following are  ten takeaways:

  1. Enterprise-wide consistency helps to mange the professionals and reduce gap risk.
  2. Regulators like to see consistency because it shows the effort an institution is putting into trying to be compliant.
  3. Communicate to Boards of Directors that OCC would like to see more focus on compliance from them
  4. Alert Suppression is okay and critical to executing priorities, but the alerts should be logged and revisited to keep the compliance programs up-to-date with the changing environment both ex-firm and intra-firm.
  5. Personal Liability of compliance officers will increase, so, keep good documentation
  6. FINRA does not target individuals, though individuals will face penalties if found willfully unaware or intentionally non-compliant. FINRA focuses on systemic risks to protect investors.
  7. FinCEN does not target individuals, especially trying to avoid dissuading the most talented compliance professionals from fleeing the most difficult problems.
  8. Intra-firm talent development is key to today’s labor market where supply of veteran compliance officers are small compared to demand.
  9. OCC intends to staff lead experts on all exams in the future.
  10. The new OCC Exam Manual, published November 11, 2014, does not have much substantive changes, mostly it is an administrative update to make sure changes to exams since the last major update are documented.

About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.
He tweets @MoneyCompliance