No Grace Period with OFAC

There is no grace period for non-compliance with the Office of Foreign Assets Control's (OFAC, part of the US Treasury Department) foreign business transaction bans, warned Allison Cooper, senior compliance officer, OFAC, at a recent National Association of Independent Insurers (NAII, Des Plaines, IL) conference.

OFAC's lists of Specially Designated Nationals (SDNs) can change daily, says Kathleen Jensen, NAII insurance services counsel. "Attendees were shocked at the answers to their compliance questions," Jensen says.

For instance, Jensen relates, one question was: If a name appears on the OFAC list today and the claim is paid tomorrow, is there a grace period? "There is no grace period," Jensen says. "If a claim is paid...the company is open to stiff sanctions from OFAC," which will be made public—resulting at the very least in a bad PR situation for the company.

OFAC's Cooper did not recommend specific tech that could help carriers meet the compliance goals of OFAC, but technologies such as software that identifies changes in names in the OFAC list could be helpful. For more information on the OFAC guidelines and the list of SDNs, visit www.treas.gov/ofac.

Greg MacSweeney is editorial director of InformationWeek Financial Services, whose brands include Wall Street & Technology, Bank Systems & Technology, Advanced Trading, and Insurance & Technology. View Full Bio