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U.S. Sanctions: Regulatory Developments

Navigating the Evolving Compliance Landscape and Analyzing Lessons From Recent Enforcement Actions

Recording of a 90-minute CLE 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, May 13, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel on sanctions compliance. The panel will examine the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) Framework one year after its implementation and will discuss recent regulatory developments. The panel will review recent enforcement actions and the lessons from those enforcement decisions. The panel will also provide best practices for sanctions compliance in the evolving landscape.


2019 included significant regulatory developments related to U.S. sanctions. In May, the OFAC issued its Framework for OFAC Compliance Commitments. The Framework provides companies with the essential components of a sanctions compliance program and a roadmap of best practices for compliance. In addition to its significant focus on compliance commitments, last year was also a record-setting year for OFAC enforcement, with penalties hitting over $1.3 billion.

In this shifting landscape, counsel to companies doing business internationally must understand OFAC’s evolving regulatory priorities and related compliance program expectations, as highlighted not only in formal agency guidance but in enforcement actions themselves.

Listen as our panel examines recent sanctions-related activity and offers strategies for developing effective, risk-based compliance programs. The panel will discuss regulatory developments and updates and examine the OFAC Compliance Framework one year after its May 2019 release. The panel will also review enforcement matters related to sanctions, and discuss the lessons learned from those matters and what they say about OFAC expectations going forward.



  1. Recent regulatory developments
  2. A Framework for OFAC Compliance Commitments: The first year
  3. Recent enforcement
    1. Lessons learned
    2. Implications for future enforcement and compliance
  4. Best practices for developing a risk-based compliance program


The panel will review these and other key issues:

  • How has the OFAC Framework changed the compliance landscape?
  • What lessons can be learned from recent enforcement actions?
  • What steps should companies take to ensure sanctions compliance? What steps should be taken to minimize potential exposure if violations occur?


Mullick, Sanjay
Sanjay José Mullick

Kirkland & Ellis

Mr. Mullick has a broad range of experience providing counsel on export controls administered by the Department of...  |  Read More

Rapa, Anthony
Anthony Rapa

Kirkland & Ellis

Mr. Rapa counsels companies, private equity sponsors, and financial institutions worldwide regarding regulatory...  |  Read More

Cotterill, Abigail
Abigail Cotterill

Of Counsel
Kirkland & Ellis

Ms. Cotterill provides legal advice to companies, financial institutions, and private equity sponsors on the regulatory...  |  Read More

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