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OFAC Compliance & Enforcement Issues:
a Guide to Minimizing the Risk of Sanctions
CLE/CPE Rebroadcast
Gerard (Jerry) W. LiVigni
Senior Compliance Officer, Office of Foreign Assets Control (OFAC)
U.S. Department of the Treasury
Mr. LiVigni has over 28 years of International Banking Operations, Anti-Money Laundering, and Bank Secrecy Act compliance experience. Before joining OFAC Jerry had been Vice President and Compliance AML Training Officer for BNP Paribas’s Bank and Securities affiliate offices in the United States. He was responsible for USA PATRIOT Act, AML policies and procedures, as well as monitoring BSA and OFAC examination work programs.
Mr. LiVigni is a key member of the Compliance Outreach and Implementation team at the Treasury Department’s Office of Foreign Assets Control (OFAC) and plays a front line role in the financial war against international terrorists, narcotics traffickers, and the addressing of OFAC sanction program regulations. He provides practical advice on a daily basis to institutions, firms, and individuals from around the world on OFAC issues, routinely interacting with his regulatory and private industry colleagues.
Mr. LiVigni has been an often requested speaker at conferences both here an abroad by regulatory, law enforcement, and private industry peers who are “concerned good actors” and are keen on having OFAC issues made clear by appealing to one’s interest and common sense. He has addressed Banks and Credit Unions; Broker-Dealers and other Security Industry Professionals; Casinos; Charities; Examiners and Regulators; MSBs; Payroll Professionals; and “other concerned individuals.” Jerry believes that the hallmark of addressing OFAC concerns either as a financial institution or a “person” who comes under OFAC jurisdiction, one ought to rely on an "ethical and reasonable approach” in one’s risk appraisal and its application.
Lorraine B. Lawlor
Chief, Compliance Outreach, Office of Foreign Assets Control (OFAC)
U.S. Department of the Treasury
Lorraine Lawlor is the Chief of Compliance Outreach at the Office of Foreign Assets Control at the U.S. Department of the Treasury. A CPA by trade, her primary responsibilities are to ensure that U.S. companies and individuals comply with U.S. economic sanctions imposed against foreign governments and groups of individuals, including terrorists and narcotics traffickers. She has been with OFAC since 1990, before which she was a Revenue Agent with the Internal Revenue Service, auditing primarily corporate tax returns. During her tenure at IRS, she was active in the Revenue Agent training program and ran workshops on small business taxation for the Small Business Administration.
At OFAC, Ms. Lawlor plays an integral role in the drafting of executive orders imposing sanctions and the regulations that implement them, as well as playing a key role in developing policy with regard to enforcement actions taken by OFAC against financial institutions. On a daily basis, she works closely with the financial and exporting communities to ensure compliance with U.S. sanctions law, working with all of the bank regulatory agencies, FinCEN, the SEC and the Commerce Department’s Bureau of Industry and Security. She played an intricate role in the development of the OFAC module in FFIEC’s AML/BSA Examination Guidelines and was a primary architect of the OFAC Enforcement Guidelines for FFIEC-Regulated Financial Institutions published in January 2006, as well as OFAC’s new Enforcement Guidelines published in September 2008. During her tenure at OFAC, she has performed innumerable audits of companies and financial institutions, as well as provided advice on potential transactions impacted by OFAC’s programs. She has conducted workshops and seminars for the financial and exporting communities across the country through such organizations as the American Bankers Association, the American Bar Association, America’s Community Bankers, and the International Financial Services Association.
In addition to her every day duties, Lorraine has been involved in several multi-lateral meetings with foreign governments in an effort to coordinate sanctions efforts and is actively involved in the Financial Action Task Force (FATF), serving as OFAC’s primary coordinator for issues addressed by that body.
Jonathan Thomas
Senior Compliance Review Coordinator, Office of Foreign Assets Control (OFAC)
U.S. Department of the Treasury
Jonathan Thomas is currently the Senior Compliance Review Coordinator at the U.S. Treasury Department's Office of Foreign Assets Control. He oversees OFAC's investigation, assessment and response to apparent violations of U.S. economic sanctions by financial institutions and has been actively involved in the implementation of OFAC's Economic Sanctions Enforcement Guidelines published in November 2009. Prior to joining OFAC, he held positions in Treasury's Office of Intelligence and Analysis and the State of Maine House of Representatives.
Steven Beattie
Anti-Money Laundering Services Leader, Financial Services
Ernst & Young LLP
Steve is the Anti-money laundering (AML) services leader for Ernst & Young. He brings operational, technology and process improvement experience starting with his prior risk and controls assessment leadership role within a global financial services company. He is responsible for Americas leadership and global coordination of Ernst & Young’s AML and economic sanctions-related efforts across banks, asset managers, broker/dealers and insurance companies. He brings extensive hands-on experience in compliance organization/structure, risk assessment and mitigation, control assessment and operational and technology improvement strategies.
The Ernst & Young team has assisted numerous organizations in evaluating and improving the completeness, appropriateness and effectiveness of their AML, OFAC and economic sanctions compliance programs and related technologies. The firm assists clients in addressing regulatory criticism, enhancing programs or to “right-size” AML and economic sanctions efforts to meet compliance objectives in a cost-effective way. Services offered include independent control assessments, process improvement support, historical transaction and/or file reviews and remediation, and program optimization.
Steve has worked and presented with various regulatory authorities as firms had endeavored to address regulatory expectation, and is a frequent speaker on current and emerging topics and challenges. Most recently, he has been a leader of industry roundtables for addressing emerging OFAC-related challenges, with particular focus on the future implications of SWIFT messaging standard changes and their resultant operational and technology impact.
Steve is frequently published on key AML and economic sanctions-related topics and facilitates industry forums and is a Certified Anti–Money Laundering Specialist (CAMS), a Certified Information Systems Auditor and a Certified Financial Services Auditor.
OFAC Compliance & Enforcement Issues: a Guide to Minimizing the Risk of Sanctions CLE/CPE Rebroadcast
Speaker Firm and Agencies:
U.S. Department of the Treasury
Upcoming events.