OFAC compliance Archives - Corruption, Crime & Compliance

14 Dec, 2022

Finding Safe Harbors Under OFAC’s Price Cap Regulations (Part III of IV)

The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector. It is even more complicated given the EU framework and another set of guidance related to the oil price cap. To ameliorate this burden, OFAC has set out detailed guidance on regulatory “safe harbors” for organizations and individuals affected...

Events

9 Nov, 2020

Webinar: The Nuts and Bolts of OFAC Sanctions Compliance

Webinar: The Nuts and Bolts of OFAC Sanctions Compliance November 19, 2020 at 12 Noon EST Sign up HERE. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) maintains a variety of sanctions programs, which can all vary in their scope and requirements. However, while OFAC sanctions can be complicated, ensuring compliance doesn’t have to be. Regardless of the program, understanding the fundamental...

General

5 Aug, 2020

OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III)

In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will review American Express and Cobham Metalics. American Express On April 30, 2020, OFAC issued a Finding of Violation (with no penalty) against American Express Travel Services for violations of the...

General

4 Aug, 2020

OFAC Enforcement and “Screening Errors” (Part I of III)

Here is another profound grasp of the obvious (for which I have a knack for delivering) – compliance and legal professionals can learn a number of lessons from individual enforcement actions. In many cases, however, there is much more to the story than the headline or the list of so-called lessons learned. One category of enforcement actions is a perfect example – OFAC has brought...

Events

27 Oct, 2019

Why A Duck — Episode 6, Coconuts and the OFAC Compliance Framework

In this Episode, Tom Fox and Mike Volkov discuss the Marx Brothers movie, Coconuts, and the new OFAC Compliance Framework. Listen HERE Tom and Mike address the following issues: Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’? How does the OFAC Framework illustrate regulatory convergence? What are some of the highlights of the OFAC Framework? What are some of the key lessons...

Podcasts

17 Mar, 2019

Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned

OFAC is off to a fast start in 2019. It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.