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Compliance Action, Volume 24, Number 1

June 06, 2019

OFAC Offers Compliance Program Framework

By Nancy Castiglione, CRCM

On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a Framework for OFAC Compliance Commitments. In other words, guidance on the essential components of a sound OFAC sanctions compliance program.

DOJ Guidance on Corporate Compliance Programs

By Nancy Castiglione, CRCM

The Criminal Division of the Department of Justice has released new guidance on evaluating corporate compliance programs.

Action Training
Solicited Faxes are no Longer Junk

By Nancy Castiglione, CRCM

The so-called “Junk Fax Prevention” Rule has been in effect since 2005 and contains some specific rules with regard to unsolicited faxes. What may not be as well-known is that solicited fax advertisements (those that have been specifically authorized by the recipient) have also been subject to similar restrictions. But, recently, those restrictions have been eased.

Incomplete Applications
The Application with an Identity Crisis

By Nancy Castiglione, CRCM

Incomplete applications have an identity crisis. They are unsure of what they are and how they want to be treated by their handlers. And, it’s no wonder. They might be an “Application” at one institution and an “Incomplete Application” at another. Let's all get on the same page.

OCC Imposes $25 Million Penalty for Fair Housing Act Violations

By Nancy Castiglione, CRCM

The OCC’s Consent Order and Order for Civil Money Penalty indicated that the violations resulted from the bank’s relationship loan pricing program.

Compliance Calendar

In the Editor's Opinion
FDIC to the Rescue for Robocalls?

By Nancy Castiglione, CRCM

You don’t usually think about the banking regulatory agencies as major robocall enforcers. That’s why it was interesting for me to see what the FDIC has done.

Compliance Notes

Compliance Q & A

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Free FDIC Training

FDIC is offering a free, live 2-hour seminar that will provide a comprehensive overview of FDIC deposit insurance and resources.

Nancy Castiglione
Editor Emeritus:
Lucy H. Griffin, Esq
Board of Advisors:
John S. Byrne, Esq.
Cliff E. Cook
David Dickinson
Julie A. Gliha
Carl G. Pry
Susan A. Rich
Robert G. Rowe, III, Esq.
Meg Sczyrba
Andy Zavoina

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