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On July 26, 2023, the U.S. Departments of Justice, Commerce, and the Treasury published a joint, or “tri-seal,” compliance note, setting forth each department’s respective voluntary self-disclosure policies that apply to potential violations of U.S. sanctions, export controls, and other national security laws. The compliance note underscores that U.S. companies, particularly those engaged in international trade and finance, play a “critical role in identifying threats from malicious actors and helping to protect our national security.”

On July 11, 2023, the U.S. Securities and Exchange Commission (SEC) announced a settled action involving a registered broker-dealer and its parent company for allegedly failing to file hundreds of Suspicious Activity Reports (SARs) from 2009 to late 2019.

On September 30, 2022, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury published its “Sanctions Compliance Guidance for Instant Payment Systems,” designed to help financial institutions allocate their compliance resources consistent with their particular sanctions risks. Although the Guidance does not purport to provide a one-size-fits-all approach, it does provide several points of guidance: (i) reaffirms that financial institutions should take a risk-based approach to managing sanctions risks; (ii) highlights key factors that may be relevant in determining that risk-based approach; (iii) encourages the development and deployment of innovative sanctions compliance approaches and technologies to address identified risks; and (iv) encourages developers of instant payment systems to incorporate sanctions compliance considerations as they develop new payment technologies.