OFAC provides guidance through enforcement

Author: | Published: 26 Feb 2019

The US agency has used recent enforcement actions to highlight the importance of maintaining sanctions compliance programmes

At a December 2018 sanctions conference in Washington, DC, Michael Dondarski, the assistant director for enforcement at US Department of the Treasury's Office of Foreign Assets Control (OFAC), spoke about how the agency uses its enforcement actions to provide guidance to the market, including in relation to compliance best practices. OFAC recently announced four settlements that serve as important reminders to international companies of (1) the importance of establishing and maintaining effective sanctions compliance programmes; and (2) the fact that OFAC will consider the quality of a company's compliance programme in weighing its enforcement decisions. Below we discuss these developments, explain why they are important for international companies to understand and identify certain key takeaways....