John Smith spoke to Thomson Reuters' Legal Executive Institute for an article covering this year's national conference for the Association of Certified Anti-Money-Laundering Specialists (ACAMS), which included a discussion of the latest developments related to the U.S. Treasury's Office of Financial Assets Control (OFAC).
"The U.S. financial system is the largest in the world, and is also the biggest risk you have as an international institution," John said. He added that in many ways, the U.S. exerts its power around through sanctions, and "OFAC has been incredibly aggressive about enforcing U.S. nexus through the U.S. financial system," meaning that financial institutions or companies that don't even do business in the U.S. can be considered by OFAC to be part of the U.S. financial system, and therefore subject to prosecution.
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