In today’s shifting political landscape, the question is can we comply?  Will we have a hit?  It is a crazy quilt of OFAC sanctions and programs that we are asked to comply with.  It is your job to manage the OFAC risk and do the best you can in this environment. Your policy, procedures and risk assessment will mitigate your risk and help your institution comply with OFAC sanctions.  What are the reports we need to complete if we get a match?  What are the steps we need to take to get the money secured?

Topics include:

• Developing a good OFAC Compliance Program
• Reports to complete—Blocking and Rejecting procedures
• How financial institutions get fined
• Audit, Training, Risk Assessments and OFAC Officer
• General and Specific Licenses and maintenance of those
• Issues with particular sanction programs
• OFAC has posted a notice of recent actions announcing it is adding new Part 520 to 31 CFR Chapter V regulations to implement Executive Order 13928 of June 11, 2020 ("Blocking Property of Certain Persons Associated With the International Criminal Court").
• OFAC is also amending the Weapons of Mass Destruction Proliferators Sanctions Regulations and Iranian Transactions and Sanctions Regulations at 31 CFR Parts 544 and 560.