Under Secretary Sigal Mandelker Remarks ABA/ABA Financial Crimes Enforcement Conference December 3, 2018

Date issued: Dec. 03 2018

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TURBOFAC Commentary (121 words)

Notes:

1) Public comments from the Under Secretary of the Treasury for Terrorism and Financial Intelligence, who oversees both OFAC and FinCEN within the U.S. Treasury.

The most notable aspect of the speech is the segment titled "OFAC’s Compliance Commitments," which outlines various expectations that "will become an essential element in settlement agreements between OFAC and apparent violators." Typically, other than to say that all entities should have a "risk based" compliance program, OFAC has been vague about what it considers to constitute best or essential practices. This appears to represent a step toward further specificity in that regard. See A Framework for OFAC Compliance Commitments (2019), setting out in detail the broad outlines of OFAC's compliance program expectations.