Six Months In. Seven Questions for an Institution’s Mid-Year Compliance Review.
OFAC enforcement activity in 2025 signaled a clear shift in expectations. The focus moved from the outcome of a decision to the process behind it and whether institutions could demonstrate the substance of their transactions exceeds the mere form of the related legal formalities. That enforcement environment shapes where many institutions now find themselves at mid-year. Months of compliance […]
Same Relationship. Different Standards.
Financial institutions operating across jurisdictions often face the challenge of applying multiple regulatory frameworks to the same relationship. As sanctions, PEP requirements, and correspondent banking expectations converge, maintaining consistency in decision-making becomes increasingly complex.
