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: Bob Walsh, 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.

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Bob Walsh

Deputy Chief Compliance Officer and Global Financial Crime Officer

AXA Group

Bob Walsh is the Deputy Chief Compliance Officer and Global Financial Crime Officer for AXA Group. AXA provides insurance, investment management and banking in over 50 countries. His main focus is ensuring compliance with international laws on anti-money laundering, international sanctions, bribery and cross-border tax evasion.

His outside activities include:
1. Industry consultation to the Financial Action Task Force and the US Bank Secrecy Act Advisory Group
2. The Financial Crime Committee of the International Association of Insurance Supervisors
3. Chairing the Sanctions in Insurance Roundtable, comprised of most major global insurance companies

Bob started his career at an international bank, and had subsequent roles as a securities regulator, and as an executive at an innovative technology firm.

Bob has a Political Science degree from McGill University, a JD from Osgoode Hall Law School and an MBA from the Ivey School of Business. He is based in New York.

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.