Every time I read the monthly OFAC Fines and Penalties page, the "name & shame" lists of American companies that have been fined for sanctions violations, one thing stands out. Most of the offenders had NO functional compliance department when they traded with sanctioned individuals, entities or governments. What's wrong with this picture ?
Every company with international business needs to avoid customers, vendors, sales staff, banks, NBFIs, and other types of individuals or entities that are sanctioned, or whom conducting trade or business with involves a sanctions violation. If you so not have a compliance officer to check the names against sanctions lists, and to review transactions for possible violations, how can you ensure that your business is not unwittingly breaking the law ?
Is it not now time to require bank clients engaged in international trade and commerce to have an operational compliance programme, particularly when they trade in the developing world ? To do any less could expose the bank to negative press, and even reputation damage, when the client's misconduct comes out. In a tactful way, you might want to ask those clients engaged in international trade about their compliance. It might just save the bank from having its name dropped into a nasty scandal.