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OFAC Compliance: Meeting Evolving U.S. Sanctions Requirements, Minimizing Risk of Sanctions

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, October 19, 2022

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel on Office of Foreign Assets Control (OFAC) compliance. The panel will discuss the new OFAC framework and OFAC’s enforcement priorities. The panel will also discuss screening, monitoring, and receiving payments, as well as offer best practices for ensuring effective sanctions compliance.


U.S. sanctions restrictions are rapidly evolving, especially in light of seismic geopolitical events like Russia’s invasion of Ukraine. Companies are facing a complex enforcement landscape that must account for global supply chains and cross-border payment flows. Consequently, it is critical to stay current on developments related to U.S. sanctions.

When the OFAC issued its new framework for compliance in 2019, it provided a roadmap for compliance. 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 OFAC’s priorities and include the essential components.

As sanctions evolve, companies and counsel must respond immediately and adjust compliance programs to ensure sanctions requirements are met. U.S. entities must assess screening and monitoring to ensure compliance and mitigate enforcement risk.

Listen as our authoritative panel guides counsel on OFAC compliance. The panel will discuss the OFAC framework and OFAC sanctions compliance priorities. The panel will also discuss the lessons from enforcement actions and provide best practices for ensuring an effective sanctions compliance program.



  1. U.S. sanctions
  2. OFAC framework
  3. Screening processes
  4. Receiving payments
  5. Blocking accounts
  6. Export and re-export requirements
  7. Steps to take if violations are suspected or discovered


The panel will review these and other key issues:

  • How did the OFAC framework change the compliance landscape?
  • What constitutes prohibited "facilitation" of a sanctions transaction?
  • What steps should companies take to ensure sanctions compliance? What are the steps to minimize potential exposure if violations occur?


O'Toole, Timothy
Timothy P. O'Toole

Miller & Chevalier

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

Fleming, Brian
Brian J. Fleming

Steptoe & Johnson

Mr. Fleming's practice matters at the intersection of national security and international trade, with an emphasis...  |  Read More

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