WASHINGTON-CUNA recently wrote a comment letter opposing a proposal by the Office of Foreign Asset Control (OFAC) to publicly disclose penalties imposed by the agency. The proposal was published in the June 19 Federal Register. “We have always been concerned that the ever-increasing complexity of the OFAC sanctions programs raises the risk that entities may mistakenly violate the requirements,” CUNA Assistant General Counsel Jeff Bloch wrote. “Publicly disclosing such violations would aggravate this potential problem by ruining the reputation of those entities that would be affected.” CUNA recommended that OFAC give violators 90 days, or longer, to come into compliance with its regulations before including them in the disclosure list, which will be published at least quarterly. Bloch wrote that the sanctions for violations are severe enough that disclosure is unwarranted, as it could lead to members losing confidence in the institution and liquidity problems. “CUNA recognizes that the goal of the proposed rule is to provide more information to the public in order to promote greater awareness of its enforcement activities and to encourage greater compliance with the OFAC sanctions program. Although we generally support efforts in favor of transparent government and disclosure of violations of law, we believe that disclosing information about OFAC penalties may unfairly impact some of the entities that are listed,” Bloch wrote. “The burdens of complying with the OFAC sanctions program are already quite substantial, which includes significant monitoring of an ever-changing list of terrorist or money laundering suspects, as well as very steep penalties for noncompliance. Although most large financial institutions use specialized software to filter or track transactions for purposes of OFAC compliance, such software is prohibitively expensive for many small credit unions.” CUNA also argued that disclosure could also exacerbate the weakened American economy.

Complete your profile to continue reading and get FREE access to CUTimes.com, part of your ALM digital membership.

Your access to unlimited CUTimes.com content isn’t changing.
Once you are an ALM digital member, you’ll receive:

  • Critical CUTimes.com information including comprehensive product and service provider listings via the Marketplace Directory, CU Careers, resources from industry leaders, webcasts, and breaking news, analysis and more with our informative Newsletters.
  • Exclusive discounts on ALM and CU Times events.
  • Access to other award-winning ALM websites including Law.com and GlobeSt.com.

Already have an account?


Credit Union Times

Join Credit Union Times

Don’t miss crucial strategic and tactical information necessary to run your institution and better serve your members. Join Credit Union Times now!

  • Free unlimited access to Credit Union Times' trusted and independent team of experts for extensive industry news, conference coverage, people features, statistical analysis, and regulation and technology updates.
  • Exclusive discounts on ALM and Credit Union Times events.
  • Access to other award-winning ALM websites including TreasuryandRisk.com and Law.com.

Already have an account? Sign In Now
Join Credit Union Times

Copyright © 2023 ALM Global, LLC. All Rights Reserved.