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Ask Me Anything –

Is This Transaction Allowed or Prohibited Under OFAC?

Often complying with OFAC sanctions is anything but clear-cut. In addition, the increasingly aggressive use of sanctions and ever-changing rules and regulations does not make compliance any easier. How many times have you wondered, “Is this transaction prohibited or not?”

The U.S. Treasury Department defines prohibited transaction as “trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute.” They further state that since the various sanctions programs have different foreign policy and national security goals, the prohibited transactions may vary.

This definition, albeit necessarily broad, illustrates how challenging it can be for a compliance officer to pin down which transactions are allowed.

Join our expert lawyers as they walk you through several scenarios meant to shed light on what is allowed and what is prohibited under OFAC.

Duration: 75 minutes

Speakers: Max Lerner, Global Head of Sanctions Compliance, State Street Bank | Devin Sefton, Senior Associate, Braumiller Law Group

Moderator: Natasha Bright, Reporter, ACSS

Date: Thursday, Oct 15, 2020

Time: 12:00 PM – 01:15 PM EST

05:00 PM – 06:15 PM London

06:00 PM – 07:15 PM Amsterdam

Our experts will test your knowledge on:

  • The 50% rule
  • General licenses and reporting requirements
  • Facilitation
  • China and Russia-related sanctions

Plus, bring any burning questions you may have about OFAC regulations so you can test our experts’ knowledge, too!

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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ACSS webinars conduct audience polls that will give you vital benchmarking data so you can measure your sanctions compliance against others.

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

Max Lerner

Global Head of Sanctions Compliance

State Street Bank

Max Lerner is the Global Head of Sanctions Compliance for State Street, a leading global bank focused in custodial, asset management and advisory, and administrative services based in Boston. Max is accountable for the design, management, and execution of State Street’s global sanctions program as well as its sanctions-related screening systems, policy and business unit advisory function, regulatory engagement and remediation, and personnel management of teams based across the globe. In his leadership role, Max is a member of State Street’s AML & Sanctions Leadership Team, wherein he advises on strategic initiatives and programmatic issues, including virtual / digital assets, cannabis, and emerging fintech solutions.

Prior to his tenure at State Street, Max served as Legal Regulatory Counsel at Standard Chartered Bank, a major global bank focused on retail, trade finance, commercial, and correspondent banking, based at its New York office. Max’s practice focused on three areas: AML & sanctions advisory, dispute resolution management, and regulatory engagement, investigations, and remediation. Max was a foundational in-house counsel advisor in the redesign and remediation of Standard Chartered’s financial crime compliance program following its multiple 2012 regulatory actions.

Max currently serves as Chair of the Association of Global Custodians’ AML & Sanctions Committee.

Devin Sefton

Senior Associate

Braumiller Law Group

Devin Sefton advises clients on a host of international trade issues, including matters pertaining to U.S. Customs and Border Protection, the Department of Commerce’s Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Department of Treasury’s Office of Foreign Assets Control, and the Committee on Foreign Investment in the U.S., among other regulatory agencies.

Devin returned to Braumiller Law Group in March 2020 after having practiced law in Washington, D.C. for several years. He has extensive experience in advising companies, both large and small, on international trade compliance. Devin’s export-related practice includes advising clients on export controls and sanctions issues, including compliance with the Export Administration Regulations, the International Traffic in Arms Regulations, and the regulations of the Office of Foreign Assets Control. He assists companies with export classification, transactional due diligence, license applications, requests for guidance, and voluntary self-disclosures, among other issues. Devin also regularly advises clients on a broad range of sanctions programs and assists in establishing global trade compliance processes and procedures. His experience in advising on cross-border transactions also includes assisting clients with matters before the Committee on Foreign Investment in the U.S. and advising on the Foreign Corrupt Practices Act.

Devin earned his law degree from the University of Texas School of Law. During law school, Devin interned with the Inter-American Court of Human Rights in San Jose, Costa Rica and studied for a semester at the University of Buenos Aires School of Law. As an undergraduate at the University of Texas at Austin, Devin majored in history and Latin American Studies and was a co-founder and editor of the Student Journal of Latin American Studies. Devin is licensed to practice law in the District of Columbia. Devin is a member of the Customs and International Trade Bar Association and the Customs Lawyers Association.