OFAC compliance
OFAC compliance in Financial & Capital Markets is under active scrutiny from the U.S. Department of the Treasury's Office of Foreign Assets Control, with the Financial Crimes Enforcement Network and the Federal Reserve Board each holding enforcement levers that reach broker-dealers, asset managers, and correspondent banking chains. OFAC's 2023 enforcement framework placed heightened expectations on financial institutions to screen not just counterparties but beneficial owners and intermediary legs in transaction chains. Firms are re-auditing SDN list screening cadences and reconciling vendor-sourced watchlist data against OFAC's current consolidated sanctions list.
Watch
- OFAC SDN List updates affecting Russian, Iranian, and Chinese-linked entities
- FinCEN beneficial ownership rule: CDD alignment deadlines for covered institutions
- Secondary sanctions exposure in correspondent banking arrangements with non-U.S. banks
- Federal Reserve supervisory letters on sanctions compliance program adequacy
- OFAC enforcement actions citing delayed screening or inadequate escalation protocols
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to ofac compliance will appear here as they are published.