Beyond the SDN List – Software, Sanctions and Shifting Priorities

Sanctions compliance is much deeper than the SDN list. Financial institutions, fintechs and service providers operating globally or using off-shore services must consider not only OFAC-administered sanctions but also programs administered by the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of State’s Directorate of Defense Trade Controls (DDTC). This session will start with an update on recent changes in U.S. sanctions policy and the impact on the payment processing industry. It will then devel into areas of sanctions and export controls that can expose financial ecosystem participants to significant liability. The session will discuss how sharing technology and software source code, even within the U.S., may be subject to export controls and how to reduce risk in providing these services. Attendees will test their knowledge through answering polling questions and judging real-life examples.