OFAC's New Economic Sanctions Enforcement Guidelines

Compliance Strategies to Withstand Tougher Foreign Asset Control Oversight

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

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Conducted on Thursday, June 11, 2009

Course Materials

This seminar will discuss OFAC's new framework for enforcement of economic sanctions, self-disclosure of possible violations and compliance programs in light of the new enforcement guidelines.


The Office of Foreign Asset Control (OFAC) issued an interim rule on economic sanctions enforcement in September that was effective immediately. While OFAC enforcement penalties are increasing, OFAC still offers strong incentives for self-disclosure of potential violations.

The new rule 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 examines OFAC’s new economic sanctions enforcement guidelines and offers their insights into best practices for companies and their counsel to ensure compliance under the new regulations.



  1. Setting the stage
    1. Origins of the new compliance guidelines
    2. Penalties then and now
  2. The new guidelines
    1. Enforcement responses
    2. Determining appropriate enforcement response
    3. Civil monetary penalty basis considerations
    4. Penalties
  3. Reaction from the business sector
    1. Potential concerns about the guidelines
    2. Insights from the comments submitted
    3. Are the new guidelines a move back to transaction specific approach?
  4. Implications of the new guidelines
    1. Compliance programs
    2. Voluntary disclosure


The panel will review these and other key questions:

  • What are the key recent changes in OFAC sanctions for businesses?
  • What are the best practices for companies to ensure compliance with foreign asset control requirements?
  • Under the latest guidelines, what are the key components of an effective OFAC compliance program?


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

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

Greta Lichtenbaum
Greta Lichtenbaum

O'Melveny & Myers

She advises in matters related to U.S. economic sanctions, export controls, antiboycott, foreign investment...  |  Read More

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