OFAC sanctions compliance: Insights from recent enforcement actions

Abstract

This paper analyses recent sanctions enforcement actions and settlements involving the United States Department of Treasury’s Office of Foreign Assets Control (OFAC). OFAC enforcement actions provide concrete examples of how deficiencies in organisations’ sanctions compliance programmes can lead to sanctions violations. The paper examines recent enforcement actions involving UniCredit Bank AG, Western Union and others, explaining how the organisations breached their obligations under OFAC sanctions laws and how OFAC applied its enforcement guidelines in applying penalties. The purpose is to provide organisations with an overview of key areas of focus for OFAC sanctions compliance, based on recent enforcement trends.