In the July 2018 edition of its Strategic Assessment journal, the Institute for National Security Studies at Tel Aviv University carries an article proposing that credit agencies should consider a bank’s OFAC violations and pending ATA lawsuits when calculating their rating, as an alternative to lawsuits and regulations to force banks into compliance.
http://www.inss.org.il/wp-content/uploads/2018/07/adkan21.2ENG_4-113-125.pdf