Getting to Grips with OFAC’s Gray Areas: An Analytical Framework for Dealing with Uncertainty
Duration: 75 minutes
Speakers: Brian Gatta, Director, Sanctions Inc.
Moderator: Natasha Bright, Reporter, ACSS
Date: Thursday, Feb 25, 2021
Time: 12:00 PM – 01:15 PM EST
05:00 PM – 06:15 PM London
06:00 PM – 07:15 PM Amsterdam
This webinar will discuss:
- The foundational principles of U.S. administrative law that govern and guide OFAC’s regulatory practices;
- The practical consequences of OFAC’s obligation to provide “fair notice” of its interpretations of ambiguous legal provisions;
- The circumstances under which it is and is not appropriate to rely on guidance provided by OFAC that addresses “sanctions program A” when you are concerned with “sanctions program B”;
- A review of some of the most frequently encountered gray areas in OFAC-administered sanctions laws, Q&A
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Brian is a Director and founder of Sanctions Inc., home of the TURBOFAC (sanctions.org) suite of post-screening sanctions solutions. Brian’s principal focus is on the maintenance and advancement of the TURBOFAC U.S. Sanctions Guided Interview System and the TURBOFAC Comprehensive U.S. Sanctions Research System and Encyclopedia. Brian’s work in creating and maintaining TURBOFAC entails the thorough review and annotation of every consequential statement attributable to OFAC, in addition to the transformation of the entirety of the OFAC-administered sanctions architecture into a single, multiple-choice “guided interview” program.
Prior to his work at Sanctions Inc., Brian spent over a decade as an attorney practicing in the international trade groups of large law firms. Brian graduated with honors from Columbia Law School in 2007.