Compliance
Compliance Corner: OFAC

The latest compliance news: regulatory developments, punishments, guidance, permissions and new product and service offerings.
The US Office
of Foreign Assets Control, which enforces US sanctions
against certain foreign countries such as Iran and Russia, has
guided firms on how it will take account of the global pandemic
in checking if businesses are complying with rules.
OFAC has said it understands that a company’s resources may be
stretched because their employees may be ill, working remotely or
furloughed.
“Organizations are facing real and serious disruptions resulting
in reduced compliance staff resources - as a result,
companies may not be able to properly screen customers/clients,
beneficial owners and third parties before conducting new
business transactions in a timely manner,” Elizabeth Slim, senior
consultant at The Volkov Law Group, said in a briefing for the
JDSupra website.
“It was only a matter of time before regulators and law
enforcement recognized the impact that the pandemic has had on
our country and our economy - The Office of Foreign Assets
Control (“OFAC”) issued guidance acknowledging that the COVID-19
crisis may impact the ability of companies to ensure compliance
with OFAC sanctions,” Slim wrote.
Slim noted: “To begin with, companies should have a
well-documented sanctions compliance program with proper policy
and procedures in place, so your organization understands its
roles and responsibilities to comply with the regulations.”
“In the face of this pandemic crisis, a business continuity plan
which defines all risks that may affect a company’s operations
during a potential threat or crisis has a developed plan to allow
the company to recover critical business functions. OFAC
sanctions screening should be listed as a critical function in
the BCP due to the regulatory risk and financial impact to your
company,” she said.
Slim added that financial institutions and other organizations
should contact OFAC as soon as possible if they are concerned
about how the pandemic affects compliance.