OFAC, FinCEN, and the SEC's BSA-Compliance Hook

What this video covers

• The core distinction between the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN): sanctions screening versus Bank Secrecy Act (BSA) reporting
• What the Specially Designated Nationals and Blocked Persons List (SDN list) is, who must be screened against it, and why ongoing re-screening is mandatory
• The difference between blocking (freezing property the firm holds) and rejecting (refusing a transaction with no blockable interest at the firm), and the reporting requirement for each
• The 10-business-day deadline for OFAC blocking reports and the September 30 annual report deadline for property blocked as of June 30
• The mechanics of FinCEN law-enforcement information-sharing requests: 14 calendar days to search, positive matches only, and the strict no-tip-off confidentiality rule
• The advance annual notice requirement and safe harbor for voluntary financial institution-to-financial institution (FI-to-FI) information sharing
• How the SEC's BSA Compliance Recordkeeping Rule creates a direct SEC enforcement hook for missed CTRs or SARs, producing concurrent FinCEN, FINRA, and SEC liability