OFAC and OFSI have released guidance that compares key aspects of both sanctions regimes, focusing on topics such as sanctions lists, recordkeeping, and reporting requirements.
OFAC
A couple of recent sanctions actions by OFAC are reminders of the need to monitor red flags and appreciate business partner risk.
Non-US financial institutions are likely to evaluate Cuba-related customers or counterparties more strictly in light of the new secondary sanctions authority.
FinCEN also seeks to oversee more of the AML/CFT supervision process by requiring US banking regulators to consult with it before undertaking certain supervisory or enforcement actions.
The settlement amount took into account the significant remedial measures TradeStation implemented after discovering the apparent violations, OFAC said.
While urging vigilance, FinCEN cautioned that firms should avoid "wholesale or indiscriminate de-risking."
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