OFAC’s Framework: Management Commitment
MANAGEMENT COMMITMENT Senior Management’s commitment to, and support of, an organization’s risk-based SCP is one of the most important factors in determining its success. This support is essential in...
View ArticleMay 3, 2019: Updated FinCEN advisory regarding Venezuelan Corruption-related...
Updated FinCEN Advisory Warns Against Continued Corrupt Venezuelan Attempts to Steal, Hide, or Launder Money Contact Public Affairs, 703-905-3770 Immediate Release May 03, 2019 WASHINGTON—The...
View ArticleOFAC’s Framework: Risk Assessment
RISK ASSESSMENT Risks in sanctions compliance are potential threats or vulnerabilities that, if ignored or not properly handled, can lead to violations of OFAC’s regulations and negatively affect an...
View ArticleMay 8, 2019: New Iran Executive Order targets Iron, Steel, Aluminum and...
On Wednesday, President Trump issued a new Iran sanctions Executive Order, which says, in part, the following: Section 1. (a) All property and interests in property that are in the United States, that...
View ArticleOFAC’s Framework: Internal Controls
INTERNAL CONTROLS An effective SCP should include internal controls, including policies and procedures, in order to identify, interdict, escalate, report (as appropriate), and keep records pertaining...
View ArticleMay 7, 2019: OFAC removes Venezuelan official from SDN List
On Tuesday, OFAC removed: CRISTOPHER FIGUERA, Manuel Ricardo, Caracas, Capital District, Venezuela; DOB 08 Nov 1963; Gender Male; Cedula No. 8375799 (Venezuela) (individual) [VENEZUELA]. from its...
View ArticleOFAC’s Framework: Testing and Auditing
TESTING AND AUDITING Audits assess the effectiveness of current processes and check for inconsistencies between these and day-to-day operations. A comprehensive and objective testing or audit function...
View ArticleOFAC’s Framework: Training
TRAINING An effective training program is an integral component of a successful SCP. The training program should be provided to all appropriate employees and personnel on a periodic basis (and at a...
View ArticleMay 9, 2019: OFAC updates NPWMD listing & SDGT, adds to Venezuela sanctions
On Friday, OFAC added the following entities: MONSOON NAVIGATION CORPORATION, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro MH96960, Marshall Islands; Identification Number IMO 5403673...
View ArticleOFAC’s Framework: Root Causes of Compliance Breakdowns and Deficiencies, #1-5
Root Causes of OFAC Sanctions Compliance Program Breakdowns or Deficiencies Based on Assessment of Prior OFAC Administrative Actions Since its publication of the Economic Sanctions Enforcement...
View ArticleOFAC’s Framework: Root Causes of Compliance Breakdowns & Deficiencies, #6-10
VI. Sanctions Screening Software or Filter Faults Many organizations conduct screening of their customers, supply chain, intermediaries, counter- parties, commercial and financial documents, and...
View ArticleMay 16, 2019: OFAC adds to Magnitsky sanctions
On May 16, OFAC added the following individuals: GEREMEYEV, Ruslan, Russia; DOB 10 May 1978; citizen Russia; Gender Male (individual) [MAGNIT]. KARLOV, Gennady Vyacheslavovich (Cyrillic: КАРЛОВ,...
View ArticleMay 17, 2019: OFAC adds to counter narcotics, global human rights sanctions
Last Friday (see, I’m slowly catching up!), OFAC added the following persons: AVELAR GUTIERREZ, Isidro, Islas Aleutianas 2307, Guadalajara, Jalisco 44540, Mexico; Santa Esther 845, Colonia Santa...
View ArticleMay 23, 2019: OFAC adds yet more to its counter narcotics sanctions
Yesterday, OFAC added the following persons: BRUNETTI, Luciano (a.k.a. “BIFF TANNEN”; a.k.a. “LUCHO”), Buenos Aires, Argentina; DOB 30 Aug 1988; POB Argentina; nationality Argentina; Gender Male;...
View ArticleOFAC Enforcement Action: You don’t see this every day…
Literally… OFAC issued a Finding of Violation, which is statistically the least frequent result of an investigation, to State Street Bank and Trust. Basically, it made pension payments to a US person’s...
View ArticleOFAC’s latest Terrorist Assets Report is out
This is OFAC’s 27th “Annual Report to the Congress on Assets in the United States Relating to Terrorist Countries and Organizations Engaged in International Terrorism” – a mouthful, I know. Some...
View ArticleJune 4, 2019: New CACR takes away group people to people travel, cruises to Cuba
On Tuesday, OFAC issued amended Cuban Asset Control Regulations (CACR), which ends group people-to-people travel. And BIS (part of the Commerce Department) amended the Export Administration Regulations...
View ArticleTreasury Department Cuba Sanctions Changes Fact Sheet
Press Release: June 4, 2019 Contact: Treasury Public Affairs, (202) 622-2960 Treasury and Commerce Implement Changes to Cuba Sanctions Rules WASHINGTON – Today, the Department of the Treasury’s Office...
View ArticleJune 6, 2019: OFAC amends 3 Venezuela General Licenses, issues FAQ
On Thursday, OFAC issued amended versions of Venezuela General Licenses 7, 8 and 13. General Licenses 8 and 13 were extended through July 27th, while section a of General License 7 “automatically...
View ArticleJune 7, 2019: OFAC sanctions Iranian petrochemical companies
On Friday, OFAC added the following entities to the Iran and non-proliferation of weapons one mass destruction (NPWMD) sanctions programs: ARVAND PETROCHEMICAL COMPANY, East 9th Floor, Building No. 46,...
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