OFAC Ballistic Missile Procurement Advisory Lists “Choke-Point” Items, Offers KYC Guidance

November 06, 2020
By: Natasha Bright, ACSS Reporter

Many different materials are needed to build a ballistic missile, some of which are items that are commonly purchased by individuals or companies who do not seek to build a weapon. Suppose you are a seller of those materials in the United States. In that case, you are obligated under sanctions law to ensure you are not conducting business with designated countries, companies, or individuals. (more…)

Targeting the Corrupt and Human Rights Abusers

June 22, 2020
By: Natasha Bright, Reporter, ACSS

The United States Office of Foreign Assets Control administers many different programs that it uses to sanction individuals and entities, including the Iran Sanctions, Non-Proliferation Sanctions, and Counter-Terrorism Sanctions. There is one specific program; however, that is instrumental in combatting severe human rights abuse or corruption in a foreign country – the Global Magnitsky Human Rights Accountability Act, or GLOMAG, program. (more…)

Celebrating First Anniversary of the “Framework for OFAC Compliance Commitments”, With a Poke at Implementation Reality

May 20, 2020
By: Jack Walsh, ACSS Reporter

Just over one year ago, in May 2019, the Office for Foreign Asset Controls (OFAC) released a 12-page framework for sanctions compliance commitments. This was the first time OFAC had ever published such detailed, prescriptive guidance, and it signaled a new desire to establish better communication with the sanctions community, particularly beyond the financial sector. (more…)

COVID-19, Humanitarian Aid, and Sanctions Compliance

May 18, 2020
By: Natasha Bright, Content Writer, ACSS

There has long been debate over the heavy-handed use of economic sanctions and whether the ends truly justify the means. In the midst of a global pandemic, however, that question has become truly salient as countries like Iran and Venezuela have increased need for humanitarian aid. Organizations like the United Nations have come out in favor of easing sanctions, while others have vehemently opposed any relief, particularly regarding Iran. (more…)

Three Designations and a Removal: Recent Major Companies Targeted by OFAC and Their Implications

May 15, 2020
By: Anna Sayre, CSS, Director of Content, ACSS

No matter how large or influential, any company that violates sanctions runs the risk of being placed on the U.S. Treasury Office of Foreign Assets Control (OFAC)’s Specially Designated Nationals (SDN) List. Once a company is considered an SDN, all U.S. persons and entities are generally prohibited from dealing with that company and all of the company’s U.S. assets are immediately frozen. (more…)

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