Joint Statement on OFAC Cyber-Related Sanction Risks

On November 5, 2018, the FFIEC released a joint statement to alert financial institutions to recent actions taken by the Treasury’s Office of Foreign Assets Control (OFAC).  These actions were taken under OFAC’s Cyber-Related Sanctions Program and have potential impact on financial institution’s operations, including the use of services of a sanctioned entity.

This statement comes in conjunction with renewed economic sanctions against the Iranian regime and warns of heightened OFAC risks due to the new sanctions.   After providing a brief background of the Cyber-Related Sanctions Program, the joint statement discusses a number of related topics such as risks, risk mitigation, OFAC compliance program risk assessments, and operational risk management.  The joint statement concludes with a list of additional resources that provide further clarification for applicable financial institutions.

The FFIEC press release and joint statement can be found here.  

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Adverse Action Reasons Chart