3rd Quarter 2022 Contents:

Case #1 – The cost of failure is high.  For years, most institutions have been lackadaisical about OFAC updates, because the risk of banking an SDN was low. But now that the SDN list has grown to more than 25,000 names, the need for stringent update procedures is absolute.

Case #2 – Everyone does it this way … but we bet they won’t anymore.  The federal courts system, in a series of actions brought by the Federal Trade Commission (FTC), has determined that  NSF fees charged by many banks are an unfair or deceptive act or practice (UDAP). Banks throughout  the country are scrambling to adjust their NSF procedures and determine who is entitled to a refund of fees. Even if your bank wasn’t part of the litigation, the ruling still applies to you.