Have I Thought of Everything When It Comes to OFAC?

This is one of those questions that keep OFAC Officers up at night.¬†Due to the complexity of¬†the¬†OFAC¬†sanctions and¬†the scope of application,¬†it is¬†a challenge to create a robust program and think of everything. However,¬†with the¬†potential¬†of fines with even one violation,¬†and the size¬†of fines being issued for multiple violations,¬†it¬†is imperative that financial institutions have a¬†strong¬†OFAC program.¬†A¬†strong¬†program must […]

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New York Cybersecurity Requirements for Banks and Financial Institutions

On March 1, 2017, the New York State Department of Financial Service‚Äôs (the ‚ÄúDFS‚ÄĚ) final cybersecurity regulations became effective (see 23 NYCRR ¬ß 500). These rules were originally published on September 13, 2016. Just before the end of the year, the DFS published another proposed regulation that eased somewhat the requirements of the original proposal […]

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