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Compliance lessons in recent Office of Foreign Assets Control enforcement

Author

Listed:
  • Hutten, Ben

    (Counsel, Buckley, USA)

Abstract

In May 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), which administers US sanctions laws, issued a broad framework identifying what OFAC views as the essential elements of risk-based sanctions compliance. At the same time, OFAC announced that it would consider how well these elements have been incorporated when considering its enforcement response to sanctions violations. While providing general guidance, the framework provides little in the way of practical detail to assist financial institutions with incorporating the framework into their organisations. Perhaps in recognition, OFAC recommended that all organisations review enforcement actions published by OFAC for purposes of reassessing and enhancing sanctions compliance. This paper is intended to help financial institutions comply with OFAC’s recommendation by identifying critical guidance and common pitfalls in a survey of post-framework enforcement actions.

Suggested Citation

  • Hutten, Ben, 2021. "Compliance lessons in recent Office of Foreign Assets Control enforcement," Journal of Financial Compliance, Henry Stewart Publications, vol. 4(3), pages 210-221, March.
    • Handle: RePEc:aza:jfc000:y:2021:v:4:i:3:p:210-221
    as

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    More about this item

    Keywords

    OFAC; sanctions; screening; diligence; risk assessment; enforcement; training; sanctions evasion; false hits;
    All these keywords.

    JEL classification:

    • G2 - Financial Economics - - Financial Institutions and Services
    • E5 - Macroeconomics and Monetary Economics - - Monetary Policy, Central Banking, and the Supply of Money and Credit
    • K2 - Law and Economics - - Regulation and Business Law

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