OFAC Compliance: Meeting Evolving U.S. Sanctions Requirements, Minimizing Risk of Sanctions
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
- work Practice Area
International
- event Date
Wednesday, October 19, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE course will guide counsel on Office of Foreign Assets Control (OFAC) compliance. The panel will discuss the new OFAC framework and OFAC’s enforcement priorities. The panel will also discuss screening, monitoring, and receiving payments, as well as offer best practices for ensuring effective sanctions compliance.
Mr. O'Toole focuses on economic sanctions and export controls. He represents companies and individuals at all stages of the process, including enforcement actions brought by the Treasury Department's Office of Foreign Asset Control (OFAC), the Commerce Department's Bureau of Industry and Security (BIS) and the U.S. Department of Justice (DOJ). He provides clients with advice on compliance with the U.S. economic sanctions and export controls laws. He also counsels and defends clients in white collar criminal matters, conducts internal corporate investigations, and represents potential witnesses and targets in government investigations.
Mr. Fleming's practice matters at the intersection of national security and international trade, with an emphasis on economic sanctions, export controls, and foreign direct investment. He uses his government experience, along with his deep understanding of US national security interests and the demands of cross-border global business, to offer practical guidance and strategies for his CFIUS clients. His practice also focuses on assisting clients with all aspects of US economic sanctions and export controls. He advises multinational companies across a range of industries in navigating the rules and regulations of the Treasury Department's Office of Foreign Assets Control (OFAC), the Commerce Department's Bureau of Industry and Security (BIS), and the State Department's Directorate of Defense Trade Controls (DDTC). He has led internal investigations regarding possible violations of economic sanctions and export control laws and has represented companies and individuals in government enforcement actions, including criminal cases brought by the DOJ.
U.S. sanctions restrictions are rapidly evolving, especially in light of seismic geopolitical events like Russia’s invasion of Ukraine. Companies are facing a complex enforcement landscape that must account for global supply chains and cross-border payment flows. Consequently, it is critical to stay current on developments related to U.S. sanctions.
When the OFAC issued its new framework for compliance in 2019, it provided a roadmap for compliance. Sanctions compliance programs should include the following crucial components: management commitment and support; risk assessment; internal controls; testing and auditing; and training. Companies should use the framework to evaluate their compliance programs to determine if they meet OFAC’s priorities and include the essential components.
As sanctions evolve, companies and counsel must respond immediately and adjust compliance programs to ensure sanctions requirements are met. U.S. entities must assess screening and monitoring to ensure compliance and mitigate enforcement risk.
Listen as our authoritative panel guides counsel on OFAC compliance. The panel will discuss the OFAC framework and OFAC sanctions compliance priorities. The panel will also discuss the lessons from enforcement actions and provide best practices for ensuring an effective sanctions compliance program.
- U.S. sanctions
- OFAC framework
- Screening processes
- Receiving payments
- Blocking accounts
- Export and re-export requirements
- Steps to take if violations are suspected or discovered
The panel will review these and other key issues:
- How did the OFAC framework change the compliance landscape?
- What constitutes prohibited "facilitation" of a sanctions transaction?
- What steps should companies take to ensure sanctions compliance? What are the steps to minimize potential exposure if violations occur?
