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
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.
- Setting the stage
- Origins of the new compliance guidelines
- Penalties then and now
- The new guidelines
- Enforcement responses
- Determining appropriate enforcement response
- Civil monetary penalty basis considerations
- Reaction from the business sector
- Potential concerns about the guidelines
- Insights from the comments submitted
- Are the new guidelines a move back to transaction specific approach?
- Implications of the new guidelines
- Compliance programs
- 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
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
He focuses on international trade policy and regulation and is a recognized authority on U.S. export controls, trade embargoes, economic sanctions, antiboycott regulations and foreign corrupt practices. He is a member of the President's Export Council Subcommittee on Export Administration, which advises on the development and implementation of U.S. export controls and security-related trade.Close
Ronald I. Meltzer
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
Mr. Meltzer 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. Mr. Meltzer 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
O'Melveny & Myers
She advises in matters related to U.S. economic sanctions, export controls, antiboycott, foreign investment... | Read More
She advises in matters related to U.S. economic sanctions, export controls, antiboycott, foreign investment (Exon-Florio), the Foreign Corrupt Practices Act, customs, and trade laws and agreements. She develops corporate compliance programs, conducts internal investigations relating to potential violations and represents companies before the relevant agencies in enforcement proceedings.Close
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