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.
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.