New Risks Created By OFAC Cyber-Related Sanctions

On November 5, 2018, the members of the Federal Financial Institutions Examination Council (FFIEC), which is comprised of the federal bank regulatory agencies, National Credit Union Administration, Bureau of Consumer Financial Protection, and State Liaison Committee, released a Joint Statement alerting financial institutions to recent actions taken by the Treasury Department's Office of Foreign Assets Control (OFAC) and the potential impact those sanctions may have on a financial institution's operations.¹ Specifically, the Joint Statement identifies the potential for OFAC violations when financial institutions engage in prohibited transactions with entities sanctioned under the Cyber-Related Sanctions Program,² as well as associated operational and cyber risks that may result from engaging directly or indirectly with sanctioned entities.