2019 was a big year for OFAC enforcement and compliance — OFAC collected $1.28 billion in fines and penalties in a total of 26 separate enforcement actions.  OFAC also issued important compliance program guidance, mandating a number of important requirements for compliance programs.

OFAC’s enforcement record for 2019 focused on supply chain sourcing; acquisition of foreign companies engaged in transactions with prohibited countries and customers; third-party distributors which re-sold to prohibited countries and customers; and compliance with specific Russia sectoral sanctions.

In this Episode, Michael Volkov reviews OFAC enforcement actions and trends and significant compliance requirements.