OFAC’s Heightened Enforcement Trends: Practical Compliance Tips and Strategies
In response to violations committed by U.S. persons as well as foreign organizations, the enforcement efforts of the Department of Treasury's Office of Foreign Assets Control (OFAC) have become more extensive. Some of the most significant OFAC enforcement actions this year include Eagle Shipping and Société Internationale de Télécommunications Aéronautiques (SITA) that were both assessed over $1 million civil penalties for their violations.
As the pace of OFAC’s enforcement actions continues to increase, stiffer probes and compliance requirements are expected to bring a complex and challenging landscape. Therefore, companies and their counsel must have comprehensive and up-to-date sanctions compliance programs to ensure maximum regulatory compliance and risk management.
In this LIVE Webcast, international trade compliance experts Samantha Sewall (Gibson, Dunn & Crutcher LLP) and Glen Lindsay (Saavedra Goodwin) will provide an in-depth discussion of recent OFAC enforcement trends. Speakers will also provide the best compliance practices and effective strategies in addressing sanctions risks.
Some of the major topics that will be covered in this course are:
- OFAC’s Recent Enforcement Actions - Key Takeaways
- Regulatory Trends and Developments
- Common Risks and Pitfalls
- Compliance Practices and Strategies
Gibson, Dunn & Crutcher LLP
- Brief Introduction to the Office of Foreign Assets Control
- What is OFAC?
- History & Policy of Economic Sanctions
- OFAC Jurisdiction
- OFAC’s Response to COVID-19
- OFAC and the SDN designation
- Definition of SDN
- Types of SDNs
- Process of Designation
- Navigating/searching the OFAC database
- Impact of OFAC designation
- Blocking of assets
- Licensure and the license application process for dealing with blocked assets
- Impact of blocking (preclusion of dealing with blocked assets and criminal penalties associated with violations)
- Supremacy of OFAC blocking statute(s)
- Commercial litigation (liens, foreclosures, etc.)
- Admiralty (maritime liens – Versilia litigation)
- Civil asset forfeiture
- Exception to OFAC supremacy: Anti-Terrorism Act/Terrorism Risk Insurance Act
- OFAC Compliance
- OFAC’s Compliance Framework released May 2019
- Top Priorities for A Successful Compliance Program
- Common Pitfalls
- Voluntary Self-Disclosure
- What Is It and Why Do It?
- New Department of Justice Policy on VSDs released December 2019
- Enforcement Trends
- Industry Trends
- 2020 Enforcement Cases Review
Who Should Attend:
- Financial Managing Officers
- Chief Financial Officers
- Compliance and Risk Officers
- Investment Advisers
- International Trade Lawyers
- Top Level Management
Samantha Sewall is an associate in the Washington, D.C. office of Gibson, Dunn & Crutcher and a member of the firm’s International Trade Practice Group.
Ms. Sewall advises clients on an array of trade compliance matters, including U.S. economic sanctions, export controls, anti-boycott, and national security reviews (CFIUS). Ms. Sewall has experience advising clients in aerospace, banking, defense, medical devices, pharmaceuticals, shipping and logistics, and travel.
Prior to joining Gibson Dunn, Ms. Sewall served as a Political-Economic Program Assistant supporting the U.S. Embassy in Côte d’Ivoire.
Samantha Sewall is an associate in the Washington, D.C. office of Gibson, Dunn & Crutcher and a member of the …
Glen Lindsay serves as Senior Litigation Counsel for Saavedra | Goodwin. Glen’s practice concentrates primarily on business, regulatory and real estate litigation with an emphasis on matters involving fraud and/or deceptive business practices as well as matters at the intersection of commercial litigation and government regulatory compliance. Glen has been, and continues to be, on the front lines of litigation matters involving OFAC and its relationship with other state and federal statutes and areas of law, including admiralty and maritime issues as well as the recent amendments to the Anti-Terrorism Act.
Glen Lindsay serves as Senior Litigation Counsel for Saavedra | Goodwin. Glen’s practice concentrates primarily on business, regulatory and real …
Print and review course materials
Method of Presentation:
General knowledge of international trade laws
NY Category of CLE Credit:
Areas of Professional Practice
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About Gibson, Dunn & Crutcher LLP
Gibson Dunn is a full-service international law firm advising on the most significant transactions and complex litigation around the world. Consistently achieving top rankings in industry surveys, Gibson Dunn is distinctively positioned in today’s global marketplace with more than 1,300 lawyers and 20 offices. The firm is known for excellence in the practice of law. It’s Global Economic and Trade Sanctions Practice Group includes some of the most experienced practitioners in the field with unparalleled global experience – many have worked extensively across Asia, Europe, the Gulf and the Americas and have served in senior government roles as principal architects of key sanctions regimes and relief including with respect to U.N. sanctions, and U.S. measures against Iran, Russia, Cuba, and Myanmar.
About Saavedra Goodwin
Established in 1988, Saavedra | Goodwin is committed to providing large firm quality representation in a small firm atmosphere, offering individualized advice, counsel, and experienced legal representation to clients in a smaller community law firm setting that is tailored to each client’s unique situation. For more than two decades, their AV rated South Florida business, litigation, real estate and aviation attorneys have provided clients around the globe with personalized, efficient service designed to achieve each client's goals.