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FinCEN recently issued a report of efforts through May 2024 to educate small businesses and other key stakeholders about new beneficial ownership reporting requirements. The report also included a list of upcoming events at which FinCEN representatives will provide information on the regulation.

The OCC has reported the key issues facing the federal banking system in its Semiannual Risk Perspective for Spring 2024.

The OCC reported that the overall condition of the federal banking system remains sound. However, the maturing economic cycle may cause consumer headwinds. It is important for banks to continue identifying material risks and their interconnected impacts. Continuous risk management improvement remains appropriate as this allows banks to guard against complacency.

The OCC highlighted credit, market, operational, and compliance risks as the key risk themes in the report.

Yesterday, the Treasury Department reported that OFAC has designated a network of two individuals and seven entities that provide major sources of revenue for U.S.-designated Republika Srpska President Milorad Dodik and his family. Dodik has used his official position to accumulate personal wealth through companies linked to himself and to Igor Dodik.

For the names and identification information of the designated parties and links to new Balkans-related General Licenses, see the June 18, 2024, BankersOnline OFAC Update.

• A Formal Agreement with Credit Suisse AG New York Branch, New York, NY, to address deficiencies in the branch’s compliance related to the Bank Secrecy Act and other anti-money laundering laws and regulations. The branch’s execution of this formal agreement was a condition for the branch’s conversion to a federal license. The provisions of the formal agreement are substantially the same as a December 2020 written agreement between the branch and the Federal Reserve Bank of New York and the New York State Department of Financial Services.
• A Formal Agreement with Touchmark National Bank, Alpharetta, GA, for unsafe or unsound practices, including those relating to the bank’s strategic planning, board and management oversight, liquidity risk management, interest risk management, credit risk management, audit, and information technology.

• Manuel Alejandro Ramirez Perez, former relationship banker and credit solutions advisor at Bonita Springs and North Naples, Florida, branches of Bank of America, N.A., Charlotte, NC, for improperly accessing customer accounts and providing information on those accounts to a third-party individual.
• Aviana Rivera, former personal banker at a Bryan, Texas, branch of First National Bank Texas, Killeen, TX, for embezzling $11,500 from the account of a bank customer.

The Treasury Department has announced that OFAC has designated two individuals and five entities that have facilitated weapons procurement for Ansarallah, commonly referred to as the Houthis. OFAC is also designating one individual and one company, as well as identifying one vessel, that have facilitated the shipment of commodities, the sale of which provides an important funding stream to the Houthis that aids in their weapons procurement. This action targets key actors who have enabled the Houthis to generate revenue and acquire a range of materials to manufacture the advanced weaponry they are now using to conduct ongoing terrorist attacks against commercial ships.

For the names and identification information of the designated parties, see the June 17, 2024, BankersOnline OFAC Update.

The Federal Reserve Board on Friday announced its issuance of a Consent Cease and Desist Order against Evolve Bancorp, Inc., and Evolve Bank & Trust, both of West Memphis, Arkansas, for deficiencies in the bank's anti-money laundering, risk management, and consumer compliance programs.

Evolve partners with various financial technology companies that, in turn, provide access to banking products and services to their end customers. Examinations conducted in 2023 found that Evolve engaged in unsafe and unsound banking practices by failing to have in place an effective risk management framework for those partnerships. In addition, Evolve did not maintain an effective risk management program or controls sufficient to comply with anti-money laundering laws and laws protecting consumers.

The Board is requiring the bank to improve its policies and programs in those areas, in addition to requiring other remedial improvements. For current partnerships with financial technology companies, the Board's action requires Evolve to strengthen its risk management practices to address potential risks, including compliance and fraud risks, by implementing appropriate oversight and monitoring of those relationships, including through enhanced procedures related to recordkeeping and consumer compliance programs. The Board's enforcement action against Evolve is independent of the bankruptcy proceedings regarding Synapse Financial Technologies, Inc.

The Board's action was taken in conjunction with the Arkansas State Bank Department, the state supervisor of Evolve.

On Friday, the Treasury Department reported that OFAC has imposed sanctions on four individuals with links to the Islamic State of Iraq and Syria (ISIS), including members of an ISIS-linked human smuggling network. The investigations into these targets, as well as their subsequent designations, were taken in close coordination with the Government of Türkiye. As a result of this close cooperation, the Government of Türkiye concurrently took its own domestic action against this network.

Also on Friday, the State Department announced its designation of Tzav 9, a violent extremist Israeli group that has been blocking, harassing, and damaging convoys carrying lifesaving humanitarian assistance to Palestinian civilians in Gaza.

For additional information on the sanctioned parties, see BankersOnline’s June 14, 2024, OFAC Update.

The Treasury Department on Wednesday announced it has issued sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its continued cruel and unprovoked war against Ukraine. Yesterday’s actions ratchet up the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain U.S. software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities both in Russia and outside its borders—including in Asia, the Middle East, Europe, Africa, Central Asia, and the Caribbean—whose products and services enable Russia to sustain its war effort and evade sanctions.

To help clarify the risk foreign financial institutions face by conducting or facilitating significant transactions or providing any service involving Russia’s designated banks, OFAC has updated the Specially Designated Nationals and Blocked Persons List (SDN List) information for five sanctioned Russian financial institutions, to include the addresses and aliases of their foreign locations.

Specifically, OFAC has updated the listings for Promsvyazbank Public Joint Stock Company to include its locations in Beijing, People’s Republic of China (PRC), Bishkek, Kyrgyz Republic, and New Delhi, India; for State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank to include its locations in Beijing, PRC and Mumbai, India; for Sberbank to include its locations in Beijing, PRC and New Delhi and Mumbai, India; for VTB to include its locations in New Delhi, India, and Beijing and Shanghai, PRC; and for VTB Capital Holdings Closed Joint Stock Company to include its location in Hong Kong, PRC.

For the names and identification information of the designated parties, and information on related OFAC actions, see the June 12, 2024, BankersOnline OFAC Update.

On June 11, the Treasury Department announced that OFAC has sanctioned members of one of Guyana’s wealthiest families, Nazar Mohamed and his son, Azruddin Mohamed, their company, Mohamed’s Enterprise, and a Guyanese government official, Mae Thomas, for their roles in public corruption in Guyana. Additionally, OFAC designated two other entities, Hadi’s World and Team Mohamed’s Racing Team, for being owned or controlled by Mohamed’s Enterprise and Azruddin, respectively. These individuals and entities are sanctioned pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world.

For the identification information of the designated parties, see the June 11, 2024, BankersOnline OFAC Update.

The Treasury Department yesterday reported that OFAC has sanctioned four individuals (including tanker captains), four entities, and two vessels in multiple jurisdictions that have engaged in the illicit transport of oil and other commodities, including for the network of Houthi financial facilitator Sa’id al-Jamal. This action targets maritime shipping and financial facilitators, several vessel managers and owners, and a company involved in forging shipping documents. This seventh round of sanctions targeting the network of Sa’id al-Jamal since October 2023 underscores the U.S. government’s commitment to isolating and disrupting the financing of international terrorist groups such as the Houthis.

For the names and identification information of the designated individuals, entities, and vessels, see the June 10, 2024, BankersOnline OFAC Update.