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    OFAC Compliance Sanctions Resources

    Below are key resources and recent guidance related to OFAC compliance, sanctions programs, and risk mitigation.

    Compliance Program Essentials

    A significant number of sanction-related enforcement actions could be avoided by putting in place the elements discussed in the guidance linked below.  Specifically, the following core elements include: i) engagement from senior management; ii) risk assessment; iii) internal controls; iv) testing; v) training. 

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    Using OFAC FAQs and the search function associated with this link, can be informative and useful in an institution’s assessment of risk and best practices around due diligence, general licenses, etc.  

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    Recent Thematic Guidance

    Enhances the Department of Treasury’s authorities to target any foreign person engaged in drug trafficking activities, regardless of whether they are linked to a specific kingpin or cartel. It further enables the Treasury to sanction foreign persons who knowingly receive property that constitutes, or is derived from, proceeds of illicit drug trafficking activities. 

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    Recent Regional/Country Specific Guidance

    Among other things, these amendments increase support for internet freedom for the Cuban people and independent Cuban private sector entrepreneurs by expanding authorizations for internet-based services and a range of financial transactions. 

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    Effective April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) replaced General License (GL) 44, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela” with a limited wind-down authorization. 

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    Effective April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) replaced General License (GL) 44, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela” with a limited wind-down authorization. 

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    Risk related to Russia, as well as sanctions specifically, are ever-changing.  As covered, specific caution for foreign financial institutions and reviewing evasion techniques.  Some recent guidance can be found here.

    Export Evasion Notice

    OFAC Alert: Russian Attemts to Evade Sanctions Using New Overseas Branches and Subsidiaries

    OFAC Alert: Possible Evasion of the Russian Oil Price Cap

    FinCEN Bank Secrecy Act Trends related to Russia

    Useful NGO Reporting on Sanctions

    In 2023, the Biden administration continued to prioritize sanctions as a key tool to support U.S. national security and foreign policy objectives. The United States added 2,500 persons—comprising 1,621 entities and 879 individuals—to the Specially Designated Nationals and Blocked Persons (SDN) list, a slight 10 percent increase from the 2,275 persons designated in 2022. 

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    Sigma360 Industry Intelligence

    Why Automated Sanction Screening is Likely Not Enough
    3 Simple Tests for Better Matching and More Efficient Name Screening
    The Nuances of Effective Sanctions Screening
     
    Getting Adverse Media Screening Right
    Adverse Media Screening Myths vs. Realities
    		 

     

     

     

    To find out more about Sigma360’s approach to advanced adverse media capabilities please  request your demo today.

    How can Sigma360 help me stay ahead? 

    Using Sigma360's risk decisioning software platform, organizations can not only get ahead of risk, but leverage unstructured data - like the screening examples highlighted in this article.  


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    Sanctions Risk Management Investigations Entity Resolution

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