The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment.  Since the pandemic, OFAC has maintained a strong profile, while managing a difficult portfolio of economic sanctions.  The last two administrations have relied on robust sanctions programs to leverage foreign policy interests. With the ongoing tension between the US and China and Russia, OFAC is going...

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;...

If you follow my blog, you know I am not one to embrace hyperbole.  So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer.  Let me explain why I am saying that. When it comes to sanctions compliance programs, most companies are well behind the curve; I am not saying they do nothing, but most...