OFAC
Essentials
CERTIFICATE COURSE
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.
Duration and Format
Includes two live virtual classes of 1.5h each
Reading assignments, prior to each class
1 hour exam
Target Audience
- OFAC/Sanctions Compliance Officers
- Audit Teams
- OFAC Analysts
- OFAC investigators
- General Counsels
- OFAC Compliance Managers
- OFAC Testing Analysts
Level
- Entry level/Intermediate
The course is delivered in an online format.
Self-paced e-learning course
Reading Assignment
Virtual Classroom #1
Reading Assignment
Virtual Classroom #2
Reading Assignment
Final assessment
Certificates of Completion and CE Credits
The course provides 7 CSS CE Credits
System requirements (for learners)
GotoTraining from Goto
Chrome browser
Learning Management System (LMS) from Litmos
Upcoming Virtual Session
Materials available: March 1, 2023
- 1st Virtual Classroom : March 8, 2023
- 2nd Virtual Classroom : March 15, 2023
Materials available: September 6, 2023
- 1st Virtual Classroom : September 13, 2023
- 2nd Virtual Classroom: September 20, 2023
Cost
ACSS Members
Non-ACSS Members
How it is structured?
Part 1 - Self-Paced E-Learning Course (30 minutes)
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 2 - Reading Assignment (60 minutes)
Part 3 - Virtual Classroom #1: Legal Authorities and How OFAC Works (90 minutes)
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 4 - Reading Assignment (30 minutes)
“Reading Assignment 2” containing key terms and definitions participants need to read to prepare for Virtual Class 2.
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 6 - Reading Assignment/Case Study (30 minutes)
Posting of Message or Question on ACSS Forum (15 minutes)
Part 7 - Final assessment (60 minutes)
Online Quiz: This is a multiple question quiz in multiple choice format.
Speaker Faculty
Scott Nance
Scott Nance from Langley Compliance Consulting. Based in DC. He is an attorney specializing in economic sanctions and anti-money laundering. He helps companies comply with economic sanctions, answering their questions about what they can and should do. Uniquely, he has worked inside several large European banks, and was the Global Head of Sanctions Compliance for ING in Amsterdam, he has also done extensive work in the fields of international trade and economic policy, and have had the opportunity to advise a number of governments in Africa and Asia on trade policy. He teaches International Trade Law and Investment at William & Mary Law School and has lectured on economic development and international trade at the University of Virginia. Scott is a member of the ACSS editorial Task force and the ACSS Certification Task Force.
Daniel Tannebaum
Daniel is a Partner and member of the Americas Risk and Public Policy Practice at Oliver Wyman. He leads the Anti-Financial Crime Practice for the Americas and serves as the firm’s Global Head of Sanctions.
Dan provides AML and Sanctions regulatory crisis management support. He also provides strategic AML and Sanctions Compliance Program support to a variety of clients. Prior to joining Oliver Wyman, he was a Partner at a global consulting firm where he supported the Global AML and Sanctions Remediation for several G-SIFIs under investigation or subject to enforcement actions.
Previously Dan served as the Head of Compliance for the Americas and Global Sanctions Champion at Travelex. Before joining Travelex, Dan was the OFAC Compliance Coordinator for the Federal Reserve Bank of New York, where he advised on OFAC issues.
Dan began his career in Compliance when he served as a Compliance Officer with OFAC.