1. Sanctions Overview
- What are sanctions and why do they matter?
- Role of OFAC (Office of Foreign Assets Control)
- Types of sanctions: Comprehensive vs. targeted
- Sanctions programs (e.g., Iran, Russia, North Korea)
2. Sanctions Background
- Legal and regulatory framework behind sanctions
- How sanctions support U.S. foreign policy and national security
- International coordination (e.g., UN, EU sanctions alignment)
3. Impact of Sanctions on Financial Institutions
- Risk exposure across banking operations
- Real-world consequences: Penalties, regulatory action, reputational damage
- Key functions affected: AML, trade finance, wire transfers, KYC/CDD
4. What to Do If a Violation Occurs
- Detection: How to identify a potential OFAC violation
- Internal escalation and reporting channels
- Immediate actions: Account freezing, transaction rejection
- Filing a Voluntary Self-Disclosure (VSD) with OFAC
- How to conduct a sanctions-related internal investigation
- Remediation strategies and demonstrating a “culture of compliance”
5. Best Practices for Sanctions Compliance
- Developing and implementing a sanctions compliance program
- Screening tools and how to use them effectively
- Third-party risk management and sanctions exposure
- Training staff to detect and report red flags
- Regular audits and program testing
6. Case Studies
- Review of actual OFAC enforcement actions
- What went wrong, and what could have been done differently
- Lessons learned from recent high-profile violations
7. Takeaways
- Actionable checklist for handling sanctions violations
- OFAC resources and guidance documents
- Template for Voluntary Self-Disclosure
- Steps to strengthen your compliance program