A.J. Bosco Gives Presentation on OFAC Sanctions at Chinese Bankers Luncheon
A.J. Bosco, Special Counsel at Zeichner Ellman & Krause LLP, has legal, compliance, and regulatory experience across many sectors of the financial services industry, and regularly advises clients on anti-money laundering, anti-bribery and corruption, financial operations, risk controls, licensing, and other regulatory and compliance issues. On January 21, 2020, A.J. delivered a presentation to the New York Chinese American Bankers Association on current trends in sanctions enforcement and how to avoid becoming the “next target.” One focus was increasing sanctions enforcement by the Office of Foreign Assets Control of the Department of the Treasury ("OFAC"). For example, in 2015, OFAC brought 15 Enforcement Actions totaling $599,705,997 in fines, while in 2019, it brought 26 Enforcement Actions totaling $1,289,027,059 in fines.
A.J. reviewed the most common ways banks run afoul of sanctions laws and the severe penalties imposed by OFAC. He then explained how best to avoid sanctions through “five pillars” of sanctions compliance: (1) Management Commitment; (2) Risk Assessment; (3) Internal Controls; (4) Testing and Auditing; and (5) Training. A lively Q & A followed the presentation. In the past, ZEK has given presentations for the group on other subjects, such as a talk on cybersecurity by Special Counsel Sean Walsh at the group’s end of year dinner gala in 2018, and a speech by Judge (and former ZEK partner) Wendy Li at the 2019 dinner gala.
The Chinese American Bankers Association includes both bank members and associate members, such as law firms, accounting firms, and insurance and real estate brokers. ZEK has been an associate member for 20 years, and partner Peter Janovsky is a member of the Board of Directors.