Economic Sanctions and Anti-Money Laundering

Penalties and Preventing Violations

The U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued new Economic Sanctions Enforcement Guidelines on September 8, 2008. The guidelines provide enforcement guidance for persons who must comply with the prohibitions and requirements of U.S. sanctions laws and regulations. The guidelines are of immediate effect and supersede the previously issued Enforcement Procedures for Banking Institutions of January 12, 2006, as well as the proposed guidelines set forth in the proposed rule of January 29, 2003, with the exception of the Cuba Penalty Schedule.

New Enforcement and Penalty Guidelines published in the Federal Register.

Economic Sanctions Developments – New Economic Sanctions Enforcement Guidelines, October 2008.

Overview Presentation: Preventing OFAC Violations: Account, Party & Transaction Screening, October 2008.

Overview Presentation: A Summary of OFAC’s New Enforcement Procedures & Penalties Guidelines, October 2008.

Exceptions to Sanctions Prohibitions – OFAC Licensing

Through licensing, OFAC makes exceptions to sweeping and comprehensive sanctions prohibitions and requirements. OFAC’s licensing function is a necessary part of the effective administration of sanctions in accordance with US government (foreign) policy. OFAC’s licensing authority is enshrined in Presidential Executive Orders imposing sanctions, and relevant underlying statutory authorities contemplate, foresee, and authorize licenses, in appropriate cases. You may have a transaction or circumstances that qualify for licensing.

Overview Presentation: OFAC Licensing – Exceptions to Economic Sanctions Prohibitions.