Beyond the Looking Glass: When You Should Block a Transaction, Terminate a Relationship or Look Back to Review Previously Processed Transactions

December 3, 2014 4:45pm

Andrea Amatuzio
Head of Sanctions
Société Générale Americas (New York, NY)

Daniel Tannebaum
Director and Global Leader, Financial Services Sanctions

Judith A. Lee
Gibson, Dunn & Crutcher LLP

  • Red and yellow flags to watch out for
  • What is considered suspicious and potentially sanctionable activity?
  • Watch out for clients that operate in countries under an OFAC sanctions program
  • Considerations for whether to take the “next step” from OFAC’s perspective
  • What is necessary for your company’s screening due diligence program?
  • How OFAC evaluates a company’s due diligence to determine if additional research would have uncovered a prohibited transaction
  • How factors in the decision to take the “next step” depends— to an extent—on the sophistication of your company