OFAC's New Economic Sanctions Enforcement Guidelines
Compliance Strategies to Withstand Tougher Foreign Asset Control Oversight
Recording of a 90-minute CLE teleconference with Q&A
Conducted on Thursday, June 11, 2009
Recorded event now available
This seminar will discuss OFAC's new framework for enforcement of economic sanctions, self-disclosure of possible violations and compliance programs in light of the new enforcement guidelines.
Description
The Office of Foreign Asset Control (OFAC) issued an interim rule on economic sanctions enforcement in September that was effective immediately. While OFAC enforcement penalties are increasing, OFAC still offers strong incentives for self-disclosure of potential violations.
The new rule provides companies some guidance on how OFAC will pursue enforcement efforts if it identifies apparent sanctions violations. Companies and their counsel must fully understand the new framework under which OFAC will assess penalties against violators.
Listen as our authoritative panel examines OFAC’s new economic sanctions enforcement guidelines and offers their insights into best practices for companies and their counsel to ensure compliance under the new regulations.
Outline
- Setting the stage
- Origins of the new compliance guidelines
- Penalties then and now
- The new guidelines
- Enforcement responses
- Determining appropriate enforcement response
- Civil monetary penalty basis considerations
- Penalties
- Reaction from the business sector
- Potential concerns about the guidelines
- Insights from the comments submitted
- Are the new guidelines a move back to transaction specific approach?
- Implications of the new guidelines
- Compliance programs
- Voluntary disclosure
Benefits
The panel will review these and other key questions:
- What are the key recent changes in OFAC sanctions for businesses?
- What are the best practices for companies to ensure compliance with foreign asset control requirements?
- Under the latest guidelines, what are the key components of an effective OFAC compliance program?
Faculty
Edward L. Rubinoff,
Partner
Akin Gump Strauss Hauer & Feld, Washington, D.C.
He focuses on international trade policy and regulation and is a recognized authority on U.S. export controls, trade embargoes, economic sanctions, antiboycott regulations and foreign corrupt practices. He is a member of the President's Export Council Subcommittee on Export Administration, which advises on the development and implementation of U.S. export controls and security-related trade.
Ronald I. Meltzer,
Partner
WilmerHale, Washington, D.C.
He focuses on licensing, compliance and enforcement matters relating to U.S. export controls and economic sanctions. He represents clients in trade remedy litigation and on customs issues. He handles all aspects of U.S. export control and economic sanctions law, including the Export Administration Regulations, anti-boycott provisions, and OFAC sanctions requirements.
Greta Lichtenbaum,
Partner
O'Melveny & Myers, Washington, D.C.
She advises in matters related to U.S. economic sanctions, export controls, antiboycott, foreign investment (Exon-Florio), the Foreign Corrupt Practices Act, customs, and trade laws and agreements. She develops corporate compliance programs, conducts internal investigations relating to potential violations and represents companies before the relevant agencies in enforcement proceedings.
Ordering
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International Law Advisory Board
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K&L Gates
Partner
Gibson Dunn & Crutcher
Partner
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WilmerHale
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Goodwin Procter
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