Wednesday, November 20, 2019
2:00 – 3:30 pm (Eastern Time)
1:00 – 2:30 pm (Central Time)
12:00 – 1:30 pm (Mountain Time)
11:00 – 12:30 pm (Pacific Time)
On June 21, 2019, the Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a final interim rule amending the reporting, procedures, and penalties regulations (RPPR) and Freedom of Information Act (FOIA) disclosures. The RPPR sets forth standard reporting and record-keeping requirements, license application, and other procedures relevant to the economic sanctions programs administered by OFAC. Among other things, the RPPR provides updated instructions and new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions.
These changes followed a May 2, 2019, publication from the US Office of Foreign Assets Control (OFAC) on A Framework for OFAC Compliance Commitment (Framework). This long-awaited document set out OFAC's expectations for effective sanctions compliance programs (SCPs).
These critical updates and changes provide for can’t-miss compliance training that provides a thorough review of the SCP Guidance along with the RPPR and FOIA Disclosures. The Instructor will also provide attendees with a Frequently Asked Questions document and targeted compliance recommendations to assist your bank in designing and implementing an SCP will meet with regulatory approval. Guidance for updating and recalibrating your bank’s auditing and testing procedures to account for changing sanctions environments is covered in an easy-to-follow format so that both new and experienced personnel will benefit from this informative session.
Section-by-Section Review of the Interim Final Rule
- Interim and Annual Blocked Property Reporting Requirements
- Overview of Changes to “Rejected Transaction” Reporting Requirements
- Scope of Rejected Transaction Reporting Obligations Under the Interim Rule
- A roadmap for OFAC compliance and recommended risk control framework
Summary of OFAC Regulations for Financial Institutions
- Transactions Subject to OFAC
- Procedure to demonstrate OFAC compliance
Review of OFAC Reporting Requirements and Audit Deficiencies
- Preparing OFAC Submission Reports
- OFAC’s five essential components of compliance
- Lessons from recent SCP enforcement actions
- The top 10 root causes of OFAC sanctions compliance program breakdowns and deficiencies
- Monitoring and audit stratagems to ensure identify potential OFAC compliance issues and program weaknesses
- Present day examination and enforcement trends
- OFAC’s baseline expectations and updated DOJ guidance
- The role of senior management in SCP risk management
- OFAC expectations with respect to sanctions-specific training
Dena Somers is a highly regarded bank consultant and compliance attorney. She has provided regulatory compliance and risk management consulting services to financial institutions and companies in highly regulated industries nationwide for more than 20 years. Her areas of expertise include consumer and mortgage lending compliance, Fintech and specialty finance, regulatory compliance training, business strategy and best practice advisement, and corporate governance. Throughout her career, Ms. Somers has advised hundreds of banking and financial institutions— ranging from local community banks to $50 billion financial holding companies— to achieve operational efficiency while ensuring regulatory compliance. Previously, Ms. Somers served as General Counsel to a national mortgage servicing company, Fintech lender, national money service business, and has represented financial institutions in a broad array of complex litigation matters for more than 15 years. Additionally, Ms. Somers is a published author for Lexis Nexis in the areas of Bank Teller training, loan policies, and loan documentation training.
1.5 CPE Credits and 1.8 AAP Credits