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OFAC Essentials Certificate Program

In order to meet the need for more in-depth training on OFAC Essentials and mitigate the risk of costly sanctions violations, we have developed an online sanctions training program, which teaches vital OFAC principles and background all OFAC sanctions compliance staff should understand.

Target audience

OFAC/Sanctions Compliance Officers

OFAC Analysts

OFAC investigators

General Counsels

OFAC Compliance Managers

OFAC Testing Analysts

What is it?

The OFAC Essentials Certificate Program is a 7-part course, consisting of approximately 7 training hours, across 4 weeks. The course is delivered in an online format.

Self-paced e-learning course

Read Participant Guide 1

Live Virtual Classroom

Read Syllabus 2

Live Virtual Classroom 2

Networking on ACSS Online Forum

Online Quiz

What Participants will get

At the end of 4 weeks, participants who successfully completed the program receive:

Certificate of Completion: Upon passing the assessment, participants will receive an electronic Certificate which denotes the completion of the course.

Credit hours (we will apply for CE credits)

System Requirements

OFAC Foundations is compatible with most operating systems and browsers to make it easy for everyone to participate. The course uses

Goto Training from Citrix or Webex

E-learning (Adobe Captivate or similar tool)

Litmos or other Learning Management System (LMS)

When ?

The OFAC Essentials Certificate Program will be offered several times per year:

September 2019 Course: Materials available as of Sept 2, with Virtual Classrooms on Sept 11 and Sept 18 (12:00 -1:30 PM ET)

December 2019 Course: Materials available as of Nov 25, with Virtual Classrooms on Dec 4 and Dec 11 (12:00 -1:30 PM ET)

Subject Matter Expert Clay Stevenson

Developed with input from OFAC subject matter expert Clay Stevens on, this ACSS program is designed to provide sanctions specialists with the training, knowledge and practical guidance needed to mitigate OFAC risks.

CLAY STEVENSON is an independent consultant specializing in economic sanctions matters, assisting clients in a variety of industries navigate the challenges of fast-changing requirements.

Prior to starting his consultancy, from 2009 to 2017 Clay was Managing Director and the Global Economic Sanctions Executive for Bank of America Corporation, responsible for the company’s economic sanctions and anti-boycott compliance efforts, as well as a stint leading its anti-bribery / anti-corruption and Code of Ethics programs.

From 2007-2009 Clay had responsibility for economic sanctions compliance at Merrill Lynch. And from 1999-2007, Clay served with the Department of the Treasury’s Office of Foreign Assets Control (OFAC), working first in the Compliance Division and later what is now the Office of Global Targeting, the group responsible for OFAC’s sanctions designation activities. Among his roles while at OFAC, Clay served as the first Chief of the Counter-proliferation Section within the then-Designation Investigations Division where he led a team of sanctions investigators charged with targeting the assets of weapons of mass destruction proliferators and their support networks, with particular focus on North Korea and Iran.

Clay received his BA from the George Washington University and his MA from the Johns Hopkins University’s School of Advanced International Studies.

Investment

ACSS Members

$495

Non-ACSS Members

$595

If you have multiple team members who can benefit from this program or wish to talk about enterprise packages, please contact for pricing and more information: helpdesk@sanctionsassociation.org or call +1-305-433-7187

How it is structured?

PART 1: Self-Paced E-Learning Course

This is a 30-minute self-paced e-learning course on the ACSS Learning Management System (LMS), which covers OFAC Essentials and Background:

  • What is OFAC and mission
  • History
  • OFAC sanctions and their objectives
  • Different types of OFAC sanctions regimes
  • Who must comply?
  • Fines
  • “OFAC online” – Where to find things on the OFAC website
PART 3: Virtual Classroom #1: Legal Authorities and How OFAC Works (1 hour and 30 minutes)

Interactive live virtual classroom (webinar with interaction, such as case studies, Q&A sessions, audience polls and practice questions.)

A Walking Tour Through main OFAC legal authorities

  • IEEPA – what is it, when enacted, where to be found, what does it do?
  • TWEA – what is it, when enacted, where to be found, what does it do?
  • Anti-Terrorism and Effective Death Penalty Act, Foreign Narcotics Kingpin Designation Act others
  • Presidential Executive Orders
  • OFAC Regulations codified at 31 CFR Ch V–main clauses
  • Short Exercise/case study/Practice questions

Categories, Principles and Core ConceptsUsed Throughout Sanctions Regimes Administered by OFAC

  • Categories: Comprehensive, vs limited, country regimes, list-based regimes, sectoral, extraterritorial, and other categories of regimes. Provide examples.
  • High level principles and core concepts or core prohibitions under Main OFAC administered Sanctions Regimes.
  • Important concepts or terms used throughout a number of OFAC administered sanctions programs (e.g. facilitation)
  • Short Exercise/case study/Practice questions

Overview of OFAC Organizational structure – who does what?

  • Sanctions Policymaking &Coordination
  • OFAC Compliance – how does OFAC assist with compliance efforts?
  • OFAC Licensing Department – How does this department work?
  • OFAC Global Targeting& Investigations
  • Short Exercise/case study/Practice questions

Q&A with audience

PART 5: Virtual Classroom #2: OFAC Risk Management and Enforcement (90 minutes)

Interactive live virtual classroom (webinar with interaction, such as case studies, Q&A sessions, audience polls and practice questions.)

Recognizing OFAC Sanctions Risks: Sound OFAC Risk Assessment

  • Inherent and residual risk.
  • How to structure a sound risk assessment and calculate risks?

OFAC Compliance Program – Control Basics

  • OFAC Policy: What should it contain?
  • Designated persons, prohibitions
  • OFAC Training: Who, what, where, when and why?
  • OFAC Independent Review
  • Short Exercise/case study/Practice questions

Customer Due Diligence and Screening

  • Prohibited Transactions
  • Due Diligence and how the 50% rule works
  • List matching/screening and assessing OFAC name matches
  • Voluntary disclosures: how to go about it?
  • Blocking and Rejecting and Reporting to OFAC
  • Releasing blocked funds
  • Short exercise /case study/Practice questions

OFAC Reporting Requirements

  • Report of Blocked and Rejected Transactions Form: Form to Use, How to Fill Out?
  • Annual Report of Blocked Property Form
  • Short Exercise/case study/Practice questions

OFAC Licenses

  • When you need a license
  • How to apply, forms to use? Where to submit
  • How long does it take?
  • Best practices and helpful tips

OFAC Enforcement:

  • OFAC Enforcement Guidelines
  • OFAC’s Administrative Subpoena (31 C.F.R. § 501.602): Process and Response.
  • Consequences of non-compliance: Penalties, and other types of actions
  • Interaction with other agencies
  • Short exercise/case study/practice questions

Q&Awith Audience

Part 2: Reading Assignment (60 minutes)

Two reading assignments containing key terms and definitions participants need to read to prepare for Virtual Class 1.

PART 4: Reading Assignment (30 minutes)

“Participant Guide 2” containing key terms and definitions participants need to read to prepare for Virtual Class 2.

PART 6: Networking

Posting of Message or Question on ACSS Forum (15 minutes)

PART 7: Final Assessment (45-minutes)

Online Quiz: This is a multiple question quiz in multiple choice format.