U.S. Regulation of International Financial Institutions: It's Time for an Integrated Approach to Compliance

In recent years, the U.S. Government has become increasingly aggressive in enforcing U.S. laws designed to regulate the conduct of financial institutions that operate in the international domain. This includes U.S.-based financial institutions that operate abroad, foreign financial institutions that operate branches or subsidiaries in the United States, and even U.S.-based financial institutions that may not operate abroad but have foreign customers or deal with foreign financial institutions. These companies face multiplying compliance concerns as they seek to comply with U.S. sanctions and anti-money laundering requirements, export-control rules, and the Foreign Corrupt Practices Act. Further complicating the compliance burden is that the U.S. Government increasingly is viewing these laws as linked and is devoting ever-higher enforcement attention to them. The author presents compliance strategies for financial institutions attempting to manage the risks posed by these complicated and nuanced laws.

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