The US Office of Foreign Assets Control (OFAC): an overview of its sanctions programmes and enforcement trends


Ms. Wendy Wysong, Partner

Mr. Ali Burney, Counsel

Mr. Nick Turner, Registered Foreign Lawyer

Clifford Chance  

The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic sanctions based on US foreign policy and national security goals. OFAC’s sanctions target not only financial institutions with a presence in the United States, but also entities that engage in transactions using U.S. dollars or involving U.S. banks in relation to conduct prohibited by US national security and foreign policy concerns. This represents a challenge for all banks as they need to comply with a more complex regulatory environment and closely monitor their customers’ activities. 
Three experts from Clifford Chance will present an overview of recent enforcement cases and sanctions programs carried out by OFAC. The presentation will include: 

  • An overview of US sanctions, OFAC’s role, and compliance for US and non-US persons.
  • Recent enforcement trends against non-US banks.
  • An overview of country-based sanctions programs.
  • Best practices for risk assessments, customer due diligence and transactions screening.

Wendy Wysong leads Clifford Chance`s Asia Pacific Anti-Corruption and Economic Sanctions Practice, maintaining offices in Hong Kong and Washington, D.C.  Her practice focuses on regulatory compliance and white collar defense of international laws, including the Foreign Corrupt Practices Act, International Traffic in Arms Regulations, Export Administration Regulations, Office of Foreign Assets Control economic sanctions, and U.S. anti-boycott laws, as well as government fraud and public corruption. 

Ali Burney focuses on international economic sanctions, export controls, anti-money laundering, and anti-bribery & corruption compliance matters. Prior to joining Clifford Chance Singapore, Ali was at Clifford Chance's Washington, DC office where he represented clients in front of US sanctions and export control enforcement agencies. Ali has more than 10 years of experience advising, conducting internal investigations and training relating to US economic sanctions, US export controls, and the Foreign Corrupt Practices Act. Prior to joining the firm, he was working as an analyst at the OFAC’s Licensing Division. 

Nick Turner specialises in financial crimes including economic sanctions and anti-money laundering advisory in the financial services sector. Nicks’s experience in North America and Asia includes trade finance, retail banking, and financial crimes compliance encompassing consent order remediation, advisory, risk assessments, and training. Prior to joining Clifford Chance, Nick worked as a compliance officer at a major US financial institution. 

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