OFAC violations by global payment processor

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.