Compliance on the High Seas: Dissecting OFAC’s Maritime Shipping Advisories To-Date

February 22, 2020
By: Benoit Beaulieu, ACSS Reporter

In accordance with sanction regimes targeting Syria’s Assad regime, North Korea, and Iran, maritime shipping has been a point of focus for sanctions authorities and those operating within their jurisdiction. This focus was prompted by the U.S. Treasury Department’s Office of Foreign Asset Controls (OFAC) issuing an advisory in 2018. OFAC has since updated this advisory in 2019 and issued another, related advisory, in 2020. (more…)

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…)

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