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When and How to Get Guidance from OFAC for Non-Bank Actors:

Tips for US and Foreign Companies

In recent years, the U.S. Office of Foreign Assets Control has proven that non-financial institutions are not immune from expensive monetary penalties for non-compliance with economic sanctions rules. So far this year, OFAC has issued more than nine million dollars in fines to four companies: a  lobbying firm, a shipping company, a Swiss telecommunications company, and even an animal nutrition company in Kansas.

While the OFAC website does have a lot of information on it, including more than 828 frequently asked questions, it isn’t necessarily easy to navigate, especially for a company that is new to the world of sanctions compliance. And, even though the agency did release more in-depth guidance on compliance programs last year, how do you know how best to apply it to your business?

Duration: 75 minutes

Speakers: James Slear, Inna Tsimerman

Moderator: Natasha Bright, Content Writer, ACSS

Date: Thursday, June 11, 2020

Time: 12:00 PM – 01:15 PM EST

05:00 PM – 06:15 PM London

06:00 PM – 07:15 PM Amsterdam

Most companies cannot afford millions of dollars in fines or the reputational damage that is done by an OFAC enforcement action.  But, how do you get necessary guidance from OFAC before you get into trouble? Should you go through a law firm? Should you call or email? Is it best to file a request for interpretive guidance or apply for a specific license?

This webinar provides answers to all these pressing questions and offers tips for both U.S. and non-U.S. companies on how to best approach working with OFAC.

Event Registration

Members of the Association

This webinar is included in your membership and you will be sent login details by email a day before the webinar.

If you would like to register for the webinar in advance, so that it is entered into your calendar.


Non Members of the Association

You must be a member in order to attend this webinar. To learn about ACSS membership, click here.

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Registered attendees can request a Certificate of Attendance to demonstrate training to auditors and regulators. For any assistance please

James Slear


Thompson Coburn

Jim Slear is a partner in the International Trade practice.  Jim advises domestic, foreign and multinational clients in a wide array of industries, including aerospace, biomedicine, defense, financial services, insurance, Internet services, manufacturing, semiconductor and telecommunications. He focuses his practice on international trade compliance and enforcement, including the economic and trade sanctions administered by the Office of Foreign Assets Control (OFAC), the International Traffic in Arms

Regulations (ITAR), the Export Administration Regulations (EAR) and the Foreign Corrupt Practices Act (FCPA). He also advises clients regarding matters before the Committee on Foreign Investment in the United States (CFIUS). 

Jim has more than 25 years of experience conducting investigations. He has conducted internal investigations for numerous clients in international trade and other matters-such as antitrust and securities–both domestically and abroad, including Europe, the Middle East, Japan, the People’s Republic of China and Malaysia. 

Prior to entering private practice, Jim was a Judge Advocate with the U.S. Air Force. During his military career, he became an accomplished trial lawyer, serving as the Air Force’s Chief Trial Counsel in Asia and later as a Federal

Court Trial Attorney for the Air Force’s Commercial

Litigation Division. He reached the rank of Lieutenant Colonel in the U.S. Air Force Reserves following 16 years on active duty. After leaving active duty in 2000, Jim spent more than ten years at the DC office of a global law firm where he advised clients on international trade compliance and enforcement matters. He also argued motions before federal and state courts and prevailed on appeal before two state supreme courts.

Inna Tsimerman

Chief International Trade Counsel


Ms. Tsimerman provides strategic advice on a broad range of trade sanctions and other international trade law issues, and on data protection issues.

Prior to her current role, Ms. Tsimerman served as the Chief Privacy & International Trade Counsel of Marsh & McLennan Companies, as corporate counsel for Marsh Clear Sight, an associate attorney at DLA Piper and at Seyfarth Shaw LLP, and an attorney in the Legal Department of CNA Insurance in Chicago. Ms. Tsimerman interned in the Legal Affairs Division of the World Trade Organization in Geneva after law school.

Ms. Tsimerman was recognized as a highly commended export and sanctions law practitioner in the 2018 World ECR Awards. She regularly speaks on a variety of sanctions law issues at conferences in the U.S. and abroad.