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OFAC Sanctions List Removal: How (and When) to File a Request for Reconsideration

The Office of Foreign Assets Control (OFAC) administers multiple sanctions programs that either prohibit or restrict financial transactions with sanctioned individuals and organizations. These individuals and organizations are identified on sanctions lists, the most well-known of which is OFAC’s list of specially designated nationals (the “SDN list”). Being placed on...

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3 Key Considerations for Entities and Individuals Under Investigation for OFAC Sanction Violations

3 Key Considerations for Entities and Individuals Under Investigation for OFAC Sanction Violations Violations of Office of Foreign Assets Control (OFAC) sanctions can have severe consequences for both entities and individuals. While financial institutions and companies can face substantial fines, individuals charged with criminal sanctions violations can face both fines...

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Blocked Transactions: What Financial Institutions Need to Know About OFAC Compliance

Financial institutions (including banks and other businesses that process financial transactions) have an obligation to avoid processing transactions that violate Office of Foreign Assets Control (OFAC) sanctions programs. This means “blocking” prohibited transactions in most cases—although sometimes financial institutions must “reject” transactions instead. Blocking and rejecting prohibited transactions (and reporting...

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What Compliance Officers Need to Know About OFAC Compliance

What Compliance Officers Need to Know About OFAC Compliance The Office of Foreign Assets Control (OFAC) regulates financial transactions between U.S. entities and specified foreign nations, businesses, and individuals. For U.S. entities that are subject to OFAC’s oversight, compliance needs to be a top priority; and, generally speaking, responsibility for...

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10 Keys to Getting Removed from OFAC’s SDN List

Being labeled a specially designated national (SDN) can have serious consequences for both individuals and organizations. As the Office of Foreign Assets Control (OFAC) explains, SDNs’ assets are “blocked,” meaning that they are subject to being frozen, and “U.S. persons are generally prohibited from dealing with them.” Since violating OFAC...

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FINRA & OFAC: What Brokerage Firms Need to Know About Compliance this Year (and Beyond)

Brokerage firms are subject to numerous compliance obligations. While most brokerage firm executives are generally familiar with the obligation to comply with the rules and regulations promulgated by the U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA), far fewer have a sufficient understanding of Office of...

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The Latest on OFAC’s and the DOJ’s Efforts to Target Tornado Cash and Other Digital Currency Mixers

The Office of Foreign Assets Control (OFAC) made a rare appearance in national headlines when it sanctioned Tornado Cash on August 8, 2022. While OFAC is among the lesser-known federal law enforcement agencies, its profile has grown in recent years—due in part to the Office’s role in combating cryptocurrency-related crime....

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10 Defense Strategies for Apparent OFAC Sanctions Violations

The Office of Foreign Assets Control (OFAC) closed 10 enforcement actions during the first eight months of 2023. These enforcement actions resulted in a total of $557 million in civil monetary penalties (CMP), with individual penalties ranging from less than $75,000 to more than $500 million. These penalties were triggered...

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The OFAC Sanctions Compliance Checklist Your Company Needs

Complying with the economic sanctions imposed by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) is difficult, even when times are quiet. When there is global upheaval and OFAC is amending its list of sanctioned individuals and companies every week, it becomes far more complicated. 2023 is...

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OFAC Risk Assessments and Reviews: A Key Aspect of Effective OFAC Compliance Management

To effectively manage Office of Foreign Assets Control (OFAC) compliance, financial institutions must not only implement robust compliance programs, but they must also assess the efficacy of their compliance programs on an ongoing basis. This involves conducting periodic risk assessments and reviews. Not only are these risk assessments and reviews...

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