Due to the death of Osama Bin Laden, a number of experts in the anti-money laundering field are predicting heightened transfers of money and assets among al-Qaeda operatives and/or leadership. Such movement could leave banks susceptible to OFAC, money laundering, and Bank Secrecy Act violations. This is particularly true in Africa, where it is believed that Al Qaeda has established a strong base in recent years.

All of this points to the need for U.S. banks to step up their efforts in relation to preventing these violations. Such efforts to prevent these violations includes staying aware of contemporary political developments. For example, over the past several months, the United States Department of the Treasury Office of Foreign Assets Control (OFAC) made several changes to the newly issued Libya sanctions including the issuance of general licenses, reporting requirements, and the designation of additional parties. These changes were in response to the constantly evolving situation in Libya.

In sum, Bin Laden’s death calls for increased compliance efforts and vigilance by U.S. banks, as it marks the beginning of a transition period for Al Qaeda and Islamic extremism. Such a period will likely involve the transfer of funds and assets amongst Al-Qaeda’s leadership. As such, there will be an opportunity for banks to catch these transfers, stop them, and block off Al-Qaeda’s funding.

As has been echoed across the world, the end of Bin Laden is not the end of terrorism. Therefore, those OFAC administered sanctions which target global terrorism are still in effect and need to be followed. As part of a larger AML/BSA program, OFAC compliance should be carefully considered during this unique to time in history. With President Obama quickly implementing sanctions against governments across the Middle East, and the rapid rate at which these sanctions programs expand and change, now more than ever OFAC compliance should be closely followed.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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