OFAC Noncompliance Leads To Big Risks For TPPP

Government agencies continue to scrutinize third-party payment processors for high-risk transactions and, when appropriate, respond to alleged violations with investigations and enforcement actions.  Industry members are most likely familiar with the numerous enforcement actions brought in recent years by the Federal Trade Commission, the Consumer Financial Protection Bureau, and the Department of Justice.  Recently, however, the Department of Treasury's Office of Foreign Assets Control (OFAC) has joined the battle, pursuing enforcement actions against and achieving multi-million dollar settlements with those alleged to have violated one or more of the U.S. sanctions programs OFAC administers.  These recent enforcement actions signal heightened focus on the payment industry and payment processors.  Consequently, these enforcement actions and settlements teach that industry members must update their OFAC compliance policies, ensure that employees comply with