Nicholas B. Johnson
Former Prosecutor
Lynette Byrd
Former Assistant
U.S. Attorney
John Sellers
Former DOJ
U.S. Attorney
Linda Julin McNamara
Former Assistant U.S. Attorney
Dr. Nick Oberheiden
Attorney & Founder
Five Things to Know About OFAC’s Requirements
Global turmoil and the war in Ukraine have made the United States drastically expand the breadth of the economic sanctions that it has imposed on foreign nationals. Using statutes passed by Congress that authorize him to do so, the President of the United States has imposed these sanctions against thousands...
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The Intersection of AML Law and OFAC Enforcement: Seven Things to Know
Money laundering is a huge issue for the Office of Foreign Assets Control (OFAC), the agency from the U.S. Department of the Treasury that is tasked with enforcing the U.S. economic sanctions that are imposed by the President of the United States. As such, there are numerous instances where OFAC’s...
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Six Tips for Complying With OFAC and FINRA Enforcement
U.S. securities professionals occupy a complex place in the global financial landscape. They manage and invest billions of dollars of other people’s money and stand between investors who want to maximize their returns and organizations who desperately need an influx of cash to expand or just to get off the...
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Civil Monetary Penalties for OFAC Violations Increase 7 Percent
Many of the civil monetary penalties for unintentional violations of the U.S. economic sanctions that are enforced by the Office of Foreign Assets Control (OFAC) at the Department of the Treasury are tied to inflation. After inflation spiked in 2022 and into 2023, OFAC announced back in January that it...
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Developing an OFAC Compliance Policy: Understanding How to Use OFAC’s Framework for Compliance Commitments
The Office of Foreign Assets Control (OFAC) does not mandate that financial institutions and businesses adopt formal compliance programs (which it refers to as “sanctions compliance programs,” or “SCP”). The agency makes this abundantly clear, bluntly stating that its regulations “do not require a formal SCP.” However, OFAC also makes...
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Avoiding Common “Root Causes” of Failure When Developing an OFAC Compliance Policy
All financial institutions—and many other types of businesses—need to have OFAC compliance policies. The Office of Foreign Assets Control (OFAC) regulates transactions between U.S. and foreign entities, and OFAC’s regulations prohibit (or “block”) transactions involving many foreign nations, companies, and individuals. These regulations establish OFAC’s various sanctions programs, and violating...
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OFAC Transaction Blocking and Rejection Compliance: What Financial Institutions Need to Know
Financial institutions in the United States have an obligation to avoid processing transactions in violation of the Office of Foreign Assets Control’s (OFAC) sanctions programs. These sanctions programs prohibit transactions involving Specially Designated Nationals (SDNs) as well as transactions that have the end result of sending funds or property to...
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Evaluating Risk, Choosing Counsel, and Other Key Considerations for OFAC Sanctions Investigations
The Office of Foreign Assets Control (OFAC) administers various sanction programs to prevent transactions with certain foreign nations, entities, and individuals. Financial institutions, companies, and individuals in the United States must strictly comply with OFAC's sanctions; and, if they fail to do so, they can face steep consequences. These consequences...
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