The latest from the Office of Foreign Assets Control may mean that vendors, suppliers, servicers and other companies providing indirect services must have effective compliance programs in place, as they cannot even indirectly support sanctioned individuals or entities.
OFAC has fined a third party provider of services for an insurance company $128,000, as it provided support services, such as:
(1) Premium processing
(3) Claims processing
(4) Claims payments
(5) Customer service
(6) Retention of agents
The support services assisted sanctioned individuals.
In an overabundance of caution, you should now advise your bank clients, who are third party processors who service any industry with foreign clients, to immediately create an effective compliance program that screens for OFAC sanctions.