In this episode of Payments Pros, Keith Barnett welcomes his colleagues Rich Zack and Christy Tuttle to discuss how U.S. government sanction programs impact payment processors, banks, and the payments industry in general.

Keith, Rich, and Christy discuss the current atmosphere of sanctions in the payments industry and the recent joint guidance issued to banks by the OCC, the Fed, and FDIC. The guidance instructs banks on the regulators’ expectations during bank examinations concerning third-party relationships, including payment processors, card issuers, blockchain, and anyone who has a form of bank partnership. The guidance covers initial due diligence, risk assessment, monitoring, ongoing due diligence, and termination of the relationship. Noncompliance with these requirements has led to sanctions against banks, payment processors, card issuers, and money transmitters.

Keith, Rich, and Christy also discuss the role of the Office of Foreign Asset Control (OFAC) in enforcing sanctions, particularly in light of the war in Ukraine, as well as the other agencies that enforce sanctions. Lastly, they also discuss what companies in the payments space can do to avoid violating sanctions, and what they should do if a violation is discovered.

Transcript: Evaluating Government Sanctions in the Payments Industry (PDF)

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Photo of Keith J. Barnett Keith J. Barnett

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts…

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

Photo of Christen Tuttle Christen Tuttle

Christen represents corporations, pharmaceutical and medical device manufacturers, health care providers, government entities, and individuals in matters involving internal investigations and investigations by state and federal law enforcement and regulatory agencies. Christen also focuses on compliance issues, particularly in the areas of health…

Christen represents corporations, pharmaceutical and medical device manufacturers, health care providers, government entities, and individuals in matters involving internal investigations and investigations by state and federal law enforcement and regulatory agencies. Christen also focuses on compliance issues, particularly in the areas of health care fraud, anti-kickback and anti-bribery, and international economic sanctions and trade controls in the health care sector. She was recently embedded in the compliance department of an international medical device company during a federal monitorship.

Photo of Richard Zack Richard Zack

Rich is a seasoned former federal prosecutor who represents financial institutions and range of other businesses and individuals facing investigation by federal and state law enforcement and regulatory authorities. He also represents business and individual victims of crime.