Secondary and Sectoral Sanctions: A Transformation in the Application of US Economic Sanctions
The economic sanctions administered and enforced by the US. Department of the Treasury’s Office of Foreign Assets Control (OFAC) are key foreign policy tools of the United States. OFAC sanctions draw their strength and extensive global influence from the US Dollar being the dominant currency in the cross-border world economy. The force and authority of US economic sanctions are frequently misinterpreted as the US exercising extraterritorial law. This is not the case.
Planning for a New AML/Anti-Fraud/Sanctions Automation System
This post is the next installment in Tim White's discussion about managing the migration from one AML transaction monitoring system to another. The first installment focused on the process of selecting a system, and avoiding vendor "pinch".
Avoiding “Vendor Pinch” when migrating to a new AML/Anti-Fraud/Sanctions Automation System
Regardless of the reason for migrating to a new Anti-Money Laundering Automation System, (System) the conversion process will likely be; costly, complex, challenging, and unfortunately protracted. Here are some things to consider as you begin considering a change.
The recent evolution of Cuban Sanctions
The changes bring us back to the Embargo’s early days! OFAC officers and compliance professionals are constantly challenged with understanding the many different sanction regimes enforced by the Office of Foreign Assets Control. Of these many sanction regimes, Cuba is the only one with some of its sanctions under the authorities of the TWEA (Trading with the Enemy Act).
Data Integrity (Model Validation)
It’s all about the data Over the last 15 to 20 years, automated transaction monitoring systems have progressed from the realm of the megabanks, to AML monitoring systems at all but the smallest institutions. They are a key resource for your institution’s AML/Anti-Fraud/Sanctions compliance program. As these systems have progressed, improved and become more commonplace, one element has remained unchanged; the key to their effectiveness is the quality and the completeness of the data they receive and the utilization of this data by the monitoring system. In making this analysis, start by looking at what information your AML system can utilize to maximize its detection and reporting capabilities; it’s all about the data.
Why I Joined the AML RightSource Team
Over the last 35 years, I have primarily been in the business of providing data and technology solutions to a wide range of financial institutions. It has been a rewarding journey to be able to assist countless financial institutions with information and cutting edge technologies to improve operational and AML and Sanctions compliance efficiencies. However, as with most things in life, it’s always execution that makes the difference. Technology and information are only as effective as the quality of the human capital putting it to use.
