Skip to main content
Menu Icon Menu Icon

In The News

Amy Davine Kim Quoted in ACFCS Article, "In Wake of OFAC Action Against Canadian Payment Processor, Banks to Review Customers, Policies"

Amy Davine Kim

Amy Davine Kim was quoted on September 29, in an article by the Association of Certified Financial Crime Specialists. According to the article, during the week of September 19, the U.S. government “launched a coordinated assault against a global network of mass mailing schemes.” These mass mailing schemes are alleged to have defrauded individuals out of hundreds of millions of dollars. The U.S. government’s move was unique since this was the “first time [OFAC] has used its powers to blacklist transnational organized criminal groups on a foreign, commercial company that helped fraudsters steal and then launder money.”

Kim commented that such developments “could be a harbinger of things to come. It puts the payment processor community on alert in yet one more area in which they need to be mindful of compliance.”

Despite prior warning from OFAC, Kim noted the company “continued doing business with [fraudulent merchants],” and that, “At least there were warning signals, according to OFAC. There was some reasonable notice before this action occurred, more than once, and the company did not stop the problematic activity.”

Kim elaborated on the company’s decision to ignore OFAC’s warnings stating, “That reaction to a government inquiry likely factored into the severity of the action.”

Click here to read the full article at

File download

Download PDF