OFAC Guidance Archives - Corruption, Crime & Compliance

Uncategorized

15 Feb, 2024

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However, that is not the corporate reality. Even after several companies are the subjects of these aggressive enforcement actions, corporate boards, senior risk managers and senior executives will turn to the chief compliance officer and ask — “do we have an effective sanctions compliance program?”...

General

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...

General

4 Nov, 2021

Ransomware and OFAC Sanctions Compliance

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering ransom payments. The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in this enforcement arena. On September 21, 2021, OFAC issued an updated ransomware advisory on the topic (“Updated Advisory”)....

Events

25 Jun, 2019

Rescheduled Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends

Rescheduled Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices and Industry Trends July 10, 2019, 12 Noon EST Sign Up Here The compliance industry is evolving. Recent DOJ and OFAC Guidance are just one influence. At the same technology and innovative strategies using data analytics are quickly eclipsing government guidance, especially in the area of compliance program monitoring, testing and auditing....

General

18 Jun, 2019

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

People disagreeing on all just about everything, yeah Makes you stop and all wonder why Why only yesterday I saw somebody on the street Who just couldn’t help but cry Oh, this ol’ river keeps on rollin’, though No matter what gets in the way and which way the wind does blow And as long as it does I’ll just sit here And watch the...