US Sanctions Violations Investigation – Multinational Australian Bank
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March 16, 2022
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FTI was engaged to map out the end-to-end sanctions of a Bank’s screening programme, at the centralised and local level across multiple jurisdictions, in order to identify any weaknesses, from a system, process or controls perspective, specifically as they may have related to screening against the OFAC Specially Designed Nationals and Blocked Persons list (‘OFAC Sanctions Screening’).
Situation
FTI was engaged by a multinational Australian bank with branches in Mainland China (the ‘Client’) to assist them in the context of a potential breach of Office of Foreign Assets Control (‘OFAC’) sanctions. FTI experts were required to map out the end-to-end sanctions screening programme, at the centralised and local level across multiple jurisdictions, in order to identify any weaknesses, from a system, process or controls perspective, specifically as they may have related to screening against the OFAC Specially Designed Nationals and Blocked Persons list (‘OFAC Sanctions Screening’).
Our Role
FTI professionals worked alongside the Client’s legal advisors, under privilege, in order to establish the detailed facts, and validate the timeline or narrative, of the Client’s relationship with certain customer entities; assess the materiality of any potential failures from an OFAC Sanctions Screening and KYC/CDD standpoint, specifically with regard to the customer entities; and to evaluate from a wider screening / programme standpoint potential weaknesses that might expose the Client to risk, as it might relate to its on-going operations and other customer relationships.
Specifically, the Client needed to ascertain whether the customer entities established, or tried to establish, relationships with its other global entities; and if the Client had exposure from a screening perspective to other ‘bad actors’.
Our Impact
FTI Consulting experts assisted the bank in ensuring they have a clear understanding of the timeline, overall exposure, and materiality of any potential failures from an OFAC Sanctions Screening and KYC/CDD standpoint. FTI Consulting further helped the Client to identify & evaluate weaknesses in its Sanctions screening/programme.
Published
March 16, 2022
Key Contacts