Banking Global Sanctions

Helping Banks Comply With Global Trade and Economic Sanctions

The increasingly complex and interrelated global economy, coupled with the inconsistent legal systems and regulatory structures of various nations, can adversely affect financial institutions.

  • Regulators are raising the bar for evaluating banks’ compliance with economic and trade sanctions. A basic “check the boxes” compliance program no longer suffices.
  • Sanctions-related compliance lapses are expensive and carry the threat of criminal prosecution for both the institution and its management.
  • The strength of compliance processes – including risk assessment, screening programs, timely identification of violations, and rapid response and disclosure – is a factor in determining whether and how much an institution is fined.

How Crowe Horwath LLP Can Help

The global sanctions advisory services specialists at Crowe combine an in-depth understanding of sanctions compliance and extensive operational risk management expertise to help banks manage their global sanctions risk management programs. Crowe global sanctions services include:

  • Helping establish Office of Foreign Assets Control (OFAC) policies and procedures
  • Coverage assessments and control inventories to identify potential weaknesses and opportunities for improvement in OFAC sanctions compliance programs
  • Risk assessments to establish an OFAC risk rating
  • Selection and implementation of sanctions screening systems
  • Validation of sanctions screening models and screening system calibration
  • Development of remediation programs in response to suspected violations
  • Anti-Money-Laundering/Bank Secrecy Act/OFAC independent audit services
  • OFAC look-backs and performance reviews to respond to regulator requirements
  • Effective quality control programs to monitor the data and the process, minimizing the impact of various elements that can create compliance program weaknesses

Independent Monitoring
Crowe offers efficient, credible third-party monitoring to meet regulators’ requirements for independent monitoring after enforcement actions or other agreements. Learn More.

Investigation and Reporting
Crowe investigators can provide fully outsourced investigative services or offer needed support to a bank’s internal financial intelligence unit. Learn More.