Foreign Assets Control Facilitation: Preparing for Expanded Enforcement in 2013
Identifying and Mitigating Risks for U.S. Persons and Companies Absent Clear Guidance
Recording of a 90-minute CLE webinar with Q&A
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.
Facilitation under OFAC
- OFAC’s broad interpretation
- What is and isn’t “facilitation”
- What is “evasion”
- Where and how do facilitation risks commonly arise
- Risks posed by U.S. persons working at foreign subsidiaries
- Risks arising when U.S. companies and non-U.S. companies collaborate
- Lessons learned from recent enforcement
Strategies for overcoming facilitation challenges/mitigating risks
- Due diligence
- Screening for third-party risks
- Managing risks with joint venture partners
- Recusal policies
The panel will review these and other key 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 key 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?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
O'Melveny & Myers
Her practice principally relates to regulations governing international business transactions and trade. She handles... | Read More
Her practice principally relates to regulations governing international business transactions and trade. She handles matters related to U.S. economic sanctions, export controls, antiboycott, and FCPA. She also assists clients to develop corporate compliance programs, conducts internal investigations relating to potential violations and represents clients in connection with enforcement proceedings.Close
Ronald I. Meltzer
He focuses on licensing, compliance and enforcement matters relating to U.S. export controls and economic sanctions. He... | Read More
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.Close