What is the difference between ofac and fincen

Kenneth A. Freis, Jr. March - August Robert W. Werner March - December William J. Fox December - February James F. Sloan April - October Stanley E. The agencies explained that the reason for the RFI is to further understand current bank practices, and determine whether additional explanation or clarification of their guidance may be helpful. Comments to the RFI must be received by June 11, In the latest development in this area, and in what appears to be a response to — or affirmation of — the Senate report, the U.

Both FinCEN and OFAC have now squarely placed an obligation on financial institutions and other payment intermediaries to put procedures in place to detect ransomware payments and to restrict payments to blocked individuals. While both FinCEN and OFAC have offered guidance to financial institutions formulating policies and procedures for deciding whether to process or report payment requests that may be connected to ransomware attacks, OFAC has also offered a warning: facilitating ransomware payments may lead to an enforcement action and civil penalties.

Last week, the Permanent Subcommittee on Investigations for the U. Although the Report ostensibly addresses the evasion of U. The Report focuses on an elaborate case study documenting how certain Russian oligarchs allegedly used transactions involving high-end art and shell companies to evade U. We will not focus on the detailed allegations in the Report regarding the particular facts of this alleged scheme, or the alleged involvement of certain major art auction houses.

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