Beyond the Looking Glass: When You Should Block a Transaction, Terminate a Relationship or Look Back to Review Previously Processed Transactions
Andrea Amatuzio
Head of Sanctions
Société Générale Americas (New York, NY)
Daniel Tannebaum
Director and Global Leader, Financial Services Sanctions
PwC LLP
Judith A. Lee
Partner
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