OFAC–Economic Sanctions Enforcement Procedures for Banking Institutions

Bank Secrecy Act (BSA)Office of the Comptroller of the Currency (OCC)Anti-Money Laundering

On January 12, 2006, the Office of Foreign Assets Control (OFAC) published in the Federal Register, “Economic Sanctions Enforcement Procedures for Banking Institutions,” along with a request for comments. OFAC will follow the published procedures when deciding whether to impose enforcement actions against banking institutions for noncompliance with its regulations. In conjunction with issuing this interim final rule, OFAC has withdrawn the January 29, 2003, proposed rule to the extent it applied to banking institutions.

The new enforcement procedures will evaluate a banking institution’s apparent OFAC-related violation in the context of the institution’s overall OFAC compliance program and specific OFAC compliance record. OFAC will not conduct such a review if no apparent violation exists within a banking institution.

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