United States:
Reassessing Your Risk Profile For OFAC Sanctions
06 January 2014
WilmerHale
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In recent years, OFAC has made the securities industry one
of its compliance and enforcement priorities. It has endorsed a
risk-based approach to compliance and listed types of transactions
that warrant additional scrutiny or due diligence. The authors
discuss the origins of this approach, common factors requiring
reassessment of risk, and typical compliance measures to deal with
it.
Originally published in the December 2013 edition of The
Review of Banking & Financial Services, Vol. 29, No.
12.
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The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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