Beyond the Looking Glass: When You Should Block a Transaction, Terminate a Relationship or Look Back to Review Previously Processed Transactions
Head of Sanctions
Société Générale Americas (New York, NY)
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