New OFAC Sanctions Compliance Framework and Guidance

Reducing Risk of Incurring U.S. Sanctions Liability, Minimizing Potential Exposure if Violations Occur

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


Conducted on Thursday, August 8, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will guide counsel on sanctions compliance. The panel will examine the new U.S. Dept. of the Treasury's Office of Foreign Assets Control (OFAC) framework and will discuss OFAC's sanctions compliance priorities. The panel will review recent enforcement actions and the lessons from those enforcement decisions. The panel will also provide best practices for applying the OFAC framework to ensure an effective sanctions compliance program.

Description

OFAC issued its Framework for OFAC Compliance Commitments in May 2019. The framework provides companies with the essential components of a sanctions compliance program and a roadmap of best practices for compliance. OFAC's enforcement guidelines set the mitigating factors OFAC uses when making enforcement decisions.

Sanctions compliance programs should include the following crucial components: management commitment and support; risk assessment; internal controls; testing and auditing; and training.

Companies should use the framework to evaluate their compliance programs to determine if they meet the OFAC priorities and include the essential components that OFAC expects in compliance programs. Failure to do so increases OFAC enforcement risk and could lead to a harsh determination by OFAC.

Listen as our authoritative panel examines the new OFAC guidance/framework on sanctions compliance. The panel will discuss OFAC's sanctions compliance priorities as well as the root causes of sanctions and will guide counsel on how to leverage these to avoid common pitfalls. The panel will also review recent enforcement actions and settlements and discuss the lessons from those enforcement decisions. The panel will provide best practices for applying the OFAC framework to ensure an effective sanctions compliance program.

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Outline

  1. New OFAC framework
  2. The interplay between OFAC sanctions compliance guidance and framework
  3. Recent enforcement actions and settlements
  4. Effective sanctions compliance program

Benefits

The panel will review these and other key issues:

  • How does the new OFAC framework change the compliance landscape?
  • What does the new framework and OFAC guidance tell counsel about the essential components of a compliance program?
  • What steps should companies take to ensure sanctions compliance? What steps should be taken to minimize potential exposure if violations occur?

Faculty

Fleming, Brian
Brian J. Fleming

Member
Miller & Chevalier

Mr. Fleming's practice focuses on investigations and compliance counseling in matters at the intersection of...  |  Read More

O'Toole, Timothy
Timothy P. O'Toole

Member
Miller & Chevalier

Mr. O'Toole focuses on economic sanctions and export controls. He represents companies and individuals at all...  |  Read More

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