Foreign Assets Control Facilitation: Identifying and Mitigating Risks for U.S. Persons and Companies

A live 90-minute CLE webinar with interactive Q&A

Tuesday, August 18, 2020

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, July 24, 2020

or call 1-800-926-7926

This CLE webinar will provide guidance for counsel to U.S. companies doing business internationally (and non-U.S. companies that have U.S. employees and operations) to identify OFAC facilitation risks, analyze recent enforcement actions, and outline approaches for mitigating facilitation risks.


As the Treasury Department's Office of Foreign Assets Control (OFAC) continues its enforcement efforts, U.S. companies with a global presence must prepare to meet the compliance challenges presented by OFAC regulations. These regulations are complicated, broad in scope, and challenging to navigate for many types of transactions.

Facilitation presents one of the most difficult OFAC compliance issues, placing U.S. persons and companies at increased risk for violations. These risks arise in different transactions and contexts, ranging from U.S. persons working at foreign subsidiaries to U.S. companies collaborating with non-U.S. companies. In addition, non-U.S. companies engaging in activities in sanctioned countries like Russia and Iran also face increased risk of so-called “secondary sanctions” if they facilitate certain significant transactions.

Counsel to U.S. companies and persons must act now to identify and mitigate facilitation risks to avoid sanctions, as well as civil and criminal penalties.

Listen as our authoritative panel examines what is and isn't considered facilitation under OFAC's broad definition, discusses how to identify facilitation risks, analyzes lessons from recent enforcement, and offers approaches for mitigating facilitation risks.



  1. Facilitation under OFAC
    1. OFAC's broad interpretation
    2. What is and isn't "facilitation"?
    3. What is "evasion"?
  2. Identifying risks
    1. Where and how do facilitation risks commonly arise
    2. Risks posed by U.S. persons working at foreign subsidiaries
    3. Risks arising when U.S. companies and non-U.S. companies collaborate
    4. Risks arising from secondary sanctions faced by non-U.S. companies
  3. Lessons from recent enforcement actions
  4. Strategies for overcoming facilitation challenges/mitigating risks
    1. Due diligence
    2. Screening for third-party risks
    3. Managing risks with joint venture partners
    4. Recusal policies
    5. Monitoring


The panel will review these and other notable questions:

  • Where do facilitation risks commonly arise?
  • What facilitation risks do U.S. companies face when collaborating with non-U.S. companies?
  • What are the critical facilitation risks faced by non-U.S. companies?
  • What policies and procedures should U.S. persons and companies put in place to minimize facilitation risks?


Lichtenbaum, Greta
Greta Lichtenbaum

O'Melveny & Myers

Ms. Lichtenbaum's practice principally relates to regulations governing international business transactions and...  |  Read More

Meltzer, Ronald
Ronald I. Meltzer

Senior Counsel
Wilmer Cutler Pickering Hale and Dorr

Mr. Meltzer focuses on licensing, compliance and enforcement matters relating to U.S. export controls and economic...  |  Read More

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