Tagged: OFAC sanctions compliance guidance

2 Dec, 2020

Five Basic Steps to Implement a Sanctions Compliance Program

Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent. Too many companies are behind the 8-ball when it comes to sanctions compliance. The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes...

General

20 Jan, 2020

2019 OFAC Sanctions Enforcement Review (Part I of II)

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase over 2018 when OFAC collected $71 million in 7 separate enforcement actions. OFAC enforcement is maturing, and its relationship with DOJ is coordinated in much the same way that...