Members of CRA’s team were hired to identify and remediate potential gaps in the compliance policy of a global payment processor. The engagement involved a review of historical transactions to locate potential violations of U.S. and global sanctions. A technical examination of payment alert systems and in-person interviews with staff were conducted to assess all aspects of the client’s compliance infrastructure. The team identified and remediated a gap that had allowed parties sanctioned by OFAC access to the payment platform.
Biden administration directs creation of sweeping new program to protect Americans’ sensitive personal data
On February 28, 2024, President Biden signed an executive order (EO), EO 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...