COMMERCIAL LENDERS MANDATED TO FIGHT WAR ON TERRORISM

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1 COMMERCIAL LENDERS MANDATED TO FIGHT WAR ON TERRORISM By Gordon L. Gerson, Esq. It has not been business as usual in the lending industry since September 11, and commercial lenders have been conscripted to help fight the war against terrorism. For many years the United States Department of Treasury has maintained lists of people involved in drug related or money laundering activities. The United States historically has implemented laws, regulations and policies which require companies that deal with the public to consult those lists and to avoid doing business with oppressive governments, international terrorists, known narcotic traffickers and other people who have been specially designated as foreign nationals with whom we are not to do business. One of the most recent laws was established on September 24, 2001, in response to the September 11 attacks on the United States. President George W. Bush signed Executive Order (the Order). The Order blocks (freezes) assets and prohibits transactions with persons who commit, threaten to commit, or support terrorism. Failure to comply with the Order can result in serious civil and criminal liability. The Order creates a several requirements that must be complied with by those involved with the extension of credit and servicing in the mortgage banking industry. The Order involves everybody involved in the mortgage banking industry. The Order specifically blocks property and prohibits transactions with the following persons: 1. Foreign persons listed in an annex to the Order (the Annex). The Annex has been supplemented numerous times since September 24, 2001 (the Annex and its supplements are collectively referred to herein as the List); 2. Foreign persons determined by the Secretary of State to have committed, or who pose a significant risk of committing, acts of terrorism that threaten the security of United States nationals or the national security, foreign policy, or economy of the United States; 3. Persons determined by the Secretary of Treasury to be owned or controlled by, or to act for or on behalf of those persons named on the List; and 4. People who have been determined by the Secretary of Treasury to assist in sponsoring or providing financial assistance to terrorist activities. The Order broadens existing authority by: 1. Expanding the coverage of existing Executive orders from terrorism in the Middle East to global terrorism; 2. Expanding the class of targeted groups to include all those who are associated with designated terrorist groups; and

2 3. Establishing the ability to block United States assets of, and deny access to United States markets to, those foreign banks that refuse to freeze terrorist assets. A copy of the List can be found on the Website of the Office of Foreign Assets Control (OFAC) at or by telephoning OFAC at (800) The events of September 11 and the continuing battle against terrorism will lead to frequent, sometimes daily, changes in the List. Because of this, it is imperative that companies check the List on a regular, if not daily, basis. OFFICE OF FOREIGN ASSETS CONTROL OFAC is a division of the U.S. Department of the Treasury. OFAC administers and enforces a series of laws that impose economic and trade sanctions against targeted foreign countries, terrorism sponsoring organizations and international drug traffickers. The parties subject to OFAC sanctions are usually identified as Specially Designated Nationals ("SDN"), Specially Designated Terrorists ("SDT"), Specially Designated Global Terrorists ("SDGT"), Specially Designated Narcotics Traffickers ("SDNT"), Foreign Terrorists Organizations ("FTO"), Blocked Persons and Blocked Vessels. Economic sanctions also apply to certain designated countries. OFAC promulgates, develops and administers sanctions under eight federal statutes. In addition to the authority granted by specific legislation, OFAC also acts under Presidential wartime and national emergency powers to impose controls on transactions and freeze the assets of oppressive governments, international terrorists, narcotics traffickers and other specially designated persons. OFAC is responsible for insuring that United States entities and persons do not engage in business transactions with enemies of the United States. The Office of General Counsel at OFAC advises persons and organizations if their activities are covered or not covered by the laws and regulations that OFAC administers. OFAC laws and regulations apply to (i) all corporations and businesses operating under US law, (ii) all American citizens and permanent resident aliens, (iii) all individuals and entities located in the United States, and (iv) all financial institutions in the United States, their affiliates, subsidiaries, foreign branches, agencies, representative offices and to all their directors, employees, officers and agents. Particular focus should be given to the the application of OFAC's laws and regulations applying to agents of financial institutions and the resulting impact on mortgage brokers acting as correspondents and agents.. The Order requires: 1. "Blocking" the funds of those persons named on the List. Pursuant to the Order, OFAC requires that all banks and other financial institutions monitor, block and

3 report every attempted transaction performed by or through them to detect those that involve any entity or person subject to OFAC laws and regulations and any persons named on the List. If a person/organization finds out that it has money that is tied in with a name on the List it is the person/organizations=s duty to block the transaction, freeze the accounts and funds so that absolutely no funds can be withdrawn and notify OFAC immediately. Once the funds have been blocked, the person/organization cannot dispose of them for any reason without permission of the government. 2. Prohibiting transactions with persons named on the List. All people/companies are expected to be immediately aware of the List, therefore a standard of Strict Liability has been implemented. 3. The prohibition on the intentional effort of organizations and individuals to violate the law. COMPLIANCE WITH OFAC LAWS AND REGULATIONS Compliance with OFAC rules and regulations is mandatory. OFACs Website at monitors OFAC changes and provides free data change notification services to all institutions. This website also contains a Policy and Procedure Manual created by OFAC. Complying with OFAC rules and regulations can be quite cumbersome and expensive, however, non-compliance with OFAC rules and regulations can result in large fines and even prison sentences. To assure compliance with OFAC, all financial institutions should create their own policy and procedure manual that follows OFAC requirements. The financial institution should first identify which transactions possess the most risk for OFAC violation. Typically these transactions will include the following: wires, new loan accounts, and customer information files ("CIF"). All transactions however should be screened to avoid OFAC violations. At the minimum, each financial institution should (i) check all of the names in its customer database, (ii) check each new customer, (iii) re-check its database every time OFAC releases new data, (iv) check each person or entity who it is entering into a transaction with and who is not a current customer, (v) check individual customers as they perform certain transactions, open new accounts, send a wire, obtain a letter of credit, etc., (vi) check all names associated with an account (including guarantors), (vii) check individual personal credit lines, (viii) check corporate personal credit lines, and (vi) purchase a software program that has been specially designed for OFAC. If, after checking the names against the List there is not a match with any names on the List, then the transaction may proceed. Be prepared to encounter a number of false positive matches (names that match those on the List but are not actually that person/entity) and have a plan of how to check a false positive.

4 If there is a match then the transaction must be blocked or in some cases, rejected and a report must be filed with OFAC. OFAC, the police and the FBI should be notified prior to contacting the individual being checked. All accounts must be frozen and placed in a locked account so that no funds can be withdrawn from the account. When a transaction is blocked or rejected, the company must comply with OFAC reporting requirements. Three of the most important reporting requirements are the following: 1. Any transaction that is blocked or rejected must be reported to OFAC within ten (10) days from the date the property became blocked. 2. An annual report of all property blocked as of June 30 is due by September 30 of each year. 3. OFAC requires the retention of all reports and blocked or rejected transaction records for five (5) years. OFAC also has the authority to issue a Alicense to do business to persons and organizations that question whether they are dealing in a permitted context. If a financial institution has blocked funds and wants to have them released, they may apply to OFAC for a specific license. Although this is probably the safest method for complying with the Order, it is very time consuming, costly and cumbersome. Federal National Mortgage Association (FNMA) and Federal Home Loan Mortgage Company (FHLMC) issued announcements, in October and December respectively. Each directed its lenders to pay attention to Executive Order and put in place steps to comply with the Order. FNMA referred to a narrower list than the List. FHLMCs announcement was more comprehensive. Although many companies follow FNMA and FHLMC procedures, OFAC requires that every type of financial transaction be reviewed for OFAC compliance including, without limitation, the following: Deposit accounts (checking, savings, etc.) Loans Lines of credit Letters of Credit Safety deposit boxes Wire transfers ACH transfers Currency exchanges Depositing or cashing checks Purchase of money orders or cashier=s checks Loan payments Guarantors and collateral owners Trust accounts Credit cards

5 OFAC also requires that the names of all parties to a transaction be checked against the List. This includes, but is not limited to the following: Beneficiaries Collateral owners Guarantors/Cosigners Receiving parties Sending parties PENALTIES FOR NON-COMPLIANCE WITH EXECUTIVE ORDER Following the Order, OFAC issued a series of regulations focusing on sanctions against terrorists, against governments who promote terrorism and against foreign organizations that are known to be tied in with terrorist activities. These regulations are still a work in progress, however, you can always find the latest developments on OFAC=s web site. Liability for not complying with the regulations can be either civil or criminal. When OFAC determines that a prohibited transaction was not blocked by a financial institution, OFAC will send the financial institution an administrative demand for information ("602 letter") asking how/why the transaction proceeded. After receiving a response to the letter, the case may be referred to the Civil Penalties Division. The Civil Penalties Division will issue a notice stating the violation and the fine. The financial institution has thirty (30) days to respond to the notice and state their reasons why the penalty should not be imposed, or, if the penalty is imposed, why amount is excessive. Two of the statutes that OFAC is currently operating under are the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act ("TWEA"). These two statutes give OFAC the authority to impose civil penalties for violations. They also give OFAC the authority to prohibit any transaction with any person or organization or any foreign government that has been determined by the President, by Executive Order, by the Congress, by Legislation, or Administratively to be tied in with some aspect of terrorism, narcotics trafficking or any other activity that seems to be a threat to the national security of the United States. Some of the criminal statutes that OFAC operates under are: 1. Code of Federal Regulations, Title 31, Part 595 prohibits the transfer, payment or other dealing with property or interest in property with specially designated terrorists that are either in the United States, or that come within the United States or within the control of United States persons. Any transactions engaged in by a United States company or a United States person with such a listed individual becomes a violation of Part 595. At the low end, the penalty for this civil violation is $11,000. The criminal penalty is up to ten (10) years in prison and

6 a $50,000 fine (IEEPA). A prosecution or enforcement action for a violation here is likely also to be coupled with a charge under the criminal laws. The criminal code includes a specific provision that increases the fine up to $250,000 per transaction for individuals and $500,000 for organizations. 2. Code of Federal Regulations, Title 31, Part 596 prohibits any United States person who knows or has reason to know that a country is designated as supporting international terrorism from engaging in a financial transaction with that government or an agency of that government. Any violation of Part 596 carries with it criminal sentence of up to ten (10) years in prison and civil fines coupled with the criminal code of up to $250,000 per transaction for individuals and $500,000 for organizations. 3. Code of Federal Regulations, Title 31, Part 597 is directed to financial institutions. It prohibits any United States financial institution that receives notice (knows or should know that this person/organization is listed) from dealing with such listed people. All financial transactions are blocked. Any violation of the financial transaction regulations carries with it criminal sentence of up to 10 years in prison and civil fines coupled with the criminal code of up to $250,000 per transaction for individuals and $500,000 for organizations. 4. The United and Strengthening America by Providing the Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the APatriot was Signed into law on October 26, The Patriot Act is aimed at money laundering. The language of the Patriot Act is very broad. The Patriot Act will involve companies that are engaged in any international business transactions, any company involved in financial relationships with foreign financial institutions, transactions with foreign investors and financial transactions that are subject to any regulatory oversight by the government. Some entities are also currently required to file a Suspicious Activity Report (SAR) every time a suspicious activity is suspected. Under the Patriot Act, SARs will most likely become applicable to everyone. Another regulation that lending institutions should be aware of is the Equal Credit Opportunity Act (ECOA) that applies to any creditor or any person who participates in the credit decision. Discrimination based on any prohibited basis, race, color, age, religion, national origin, gender or marital status is not allowed. This includes discrimination against Muslims. All employers should exert extra caution when hiring employees to assure that they are not hiring foreign nationals who are on the List. However, each employer must conduct business within the ECOA guidelines. Triggering an ECOA violation is more likely than

7 triggering a violation of OFAC, therefore ECOA violations should be monitored as closely as the List. CONCLUSION To date, the authority of OFAC has seldom been challenged in any court. Now that OFAC is involved in anti-terrorism, some of the companies and individuals that are affected by the controls will most likely seek to clarify some of the aspects of these regulations in Court. To ensure compliance with Executive Order and with all of OFAC's rules and regulations, to avoid penalties and to avoid litigation, each financial institution should create a policy and procedure manual. Each employee involved in extending credit or accepting deposits or payments, should be educated and trained on the requirements of Executive Order and OFAC. The List should be checked daily and copies of all whether false or positive, should be kept. OFAC requirements should be checked regularly and updates should be logged and the information distributed throughout the company.

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