Tagged: OFAC Sanctions Compliance Programs

various cryptocurrency on table

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a post on sanctions compliance in the cryptocurrency industry. Matt can be contacted at [email protected] In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher course for sanctions compliance.  While the guidance was...

Episode 174: Five Basic Steps to Implement a Sanctions Compliance Program

Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements.  Companies ignore the SCP Guidance at their peril.   The Treasury Department’s Office of Foreign Asset Control (OFAC) has a robust and mature enforcement program.  Over the last few years, OFAC has successfully expanded its enforcement...

OFAC Screening and Internal Controls

Companies have had over one year to review and implement a sanctions compliance guidance program.  This last year, however, has been difficult (to say the least) given the COVID-19 pandemic.  Companies have had unusual challenges.  OFAC recognized the impact of COVID-19 when it issued guidance in April 2020 recognizing that companies faced challenging times and may have reallocated resources to meet pandemic needs. Prior to...

Episode 90 — OFAC Issues New Framework for Sanctions Compliance Program

On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”).  Together with its aggressive enforcement of economic sanctions, OFAC has set a new standard for SCPs, and has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a...