Foreign Asset Control Compliance in Domestic and International Transactions

Avoiding Penalties in the New Enforcement Environment

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Tuesday, October 6, 2009

Recorded event now available

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Course Materials

This seminar will offer guidance to legal advisers in understanding the government's requirements for foreign asset control compliance, in navigating the current enforcement environment, and in developing best practices for ensuring compliance with OFAC regulations.


The federal government continues to aggressively police multi-national business relationships. Stringent economic sanctions and export controls aimed at foreign countries, entities and people affect the American business operations in unexpected ways.

Companies engaged in domestic transactions that involve foreign entities must be aware of the Specially Designated Nationals and Blocked Persons list and of conduct prohibited by the Office of Foreign Assets Control (OFAC).

OFAC's interim rule on economic sanctions 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 of attorneys guides business legal advisors in understanding the government's requirements and in navigating the current enforcement environment. The panel will outline best practices for counsel to ensure compliance with OFAC regulations.



  1. Landscape/overview
    1. Covered countries
    2. Covered entities and individuals
    3. Laws covering economic sanctions
    4. Scope of sanctions
    5. Recent changes to U.S. sanctions
  2. Enforcement environment
    1. OFAC’s interim rule on economic sanctions enforcement
    2. Audits and investigations
    3. Voluntary disclosures
    4. Penalties
    5. What can be learned from recent enforcement actions?
  3. Compliance programs
    1. Core elements
    2. Mergers and acquisitions


The panel will review these and other key questions:

  • What is the scope of the OFAC sanctions and what conduct is prohibited?
  • How have the enforcement guidelines changed the enforcement environment? What can be learned from recent enforcement actions?
  • What are the best practices for businesses to ensure compliance with foreign asset control requirements?
  • What are the key elements for an effective compliance program?


Erin L. Crockett
Erin L. Crockett
Director, Corporate Global Trade Compliance

She is responsible for the Dresser, Inc.’s, recently purchased by GE Energy, a division of GE, Global Trade...  |  Read More

Judith A. Lee
Judith A. Lee

Gibson Dunn & Crutcher

Ms. Lee's practice focuses on international trade regulation, including USA Patriot Act compliance, Foreign...  |  Read More

Edward L. Rubinoff
Edward L. Rubinoff

Akin Gump Strauss Hauer & Feld

He focuses on international trade policy and regulation and is a recognized authority on U.S. export controls, trade...  |  Read More

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