The Treasury Department's Office of Foreign Assets Control (OFAC) has aggressively pursued enforcement of global sanctions regulations. During the height of the Covid-19 pandemic, OFAC issued guidance suggesting a relaxed approach to sanctions enforcement. In the last few months, however, OFAC has resumed its aggressive enforcement strategy.
Many of OFAC's enforcement actions are initiated through voluntary self-disclosure. Under OFAC's Enforcement Guidelines, companies earn valuable rewards by self-disclosing potential violations, conducting an important internal investigation, reporting the results to OFAC, and remediating any deficiencies in the company's compliance program.
Global companies face extraordinary risks in sanctions compliance. In May 2019, OFAC issued important compliance guidance, A Framework for Sanctions Compliance Commitments, which outlined a broad set of compliance program requirements and expectations. In light of OFAC's aggressive enforcement program, OFAC's Compliance Guidance underscores important issues, including senior management commitment, risk assessments, internal controls and technology, training and testing and audits.
In this webinar, Michael Volkov, Principal of The Volkov Law Group, will review recent OFAC enforcement actions and trends. He will also examine the benefits of OFAC's voluntary disclosure program and outline important issues and considerations when deciding whether to voluntarily self disclose a potential violation. Finally, Mike will outline OFAC's comprehensive compliance program guidance, discuss the important elements of a program, and ways in which you can meet those requirements.
Register here: https://register.gotowebinar.com/register/2519250929766449420
1 hour of Texas CLE pending.
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