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OFAC encourages communication regarding compliance concerns related to COVID-19

  • United Kingdom
  • Fraud and financial crime
  • Litigation and dispute management

22-04-2020

The Office of Foreign Assets Control (OFAC) has encouraged the communication of any OFAC compliance concerns related to COVID-19. As part of this, OFAC has provided the following guidance and contact information.

Sanctions Programmes Fact Sheet

On 16 April 2020, OFAC published a fact sheet which highlights the most relevant exemptions, exceptions and authorisations for humanitarian assistance and trade under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia sanctions programmes. The hope is that this will assist individuals, governments and entities with any questions they may have in relation to the provision of humanitarian assistance to sanctions countries.

Meeting regulatory associated deadlines

OFAC has urged persons, including financial institutions, to make contact as soon as practicable if there is a belief that there may be any delays in meeting deadlines associated with OFAC regulated requirements. This includes, but is not limited to, filing blocking and reject reports within the required ten business days and the provision of reports required by general or specific licenses. OFAC also requests that self-disclosures should be made via e-mail to OFACdisclosures@treasury.gov rather than by physical mail.

Technical and source challenges

If an organisation is facing technical and resource challenges as a result of COVID-19 and decides to temporarily reallocate sanctions compliance resources as a result of its risk-based approach to sanctions compliance, OFAC has stated that it will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period. Such issues will be addressed on a case-by-case basis. This is a welcome development and provides some potential breathing space for legal and compliance teams having to juggle regulatory obligations, particularly global financial institutions which will have competing requirements across multiple jurisdictions.

The link to the advisory can be found here.