OFAC Enforcement & Compliance

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Can Your Sanctions Compliance Program Sustain the Heat of Increased International Enforcement?

The Treasury Department’s Office of Foreign Assets Controls (OFAC) is stepping up enforcement of U.S. economic sanctions.

Companies operating in the global market face significant challenges as stricter and broader restrictions are imposed to prevent trade or financial transactions with targeted governments or entities. Risks associated with U.S. embargo programs are also increasing, as companies are restricted from doing business with third-country entities and persons acting on behalf of a sanctioned government.

With the dramatic increase in penalties amounts under IEEPA and new OFAC enforcement guidelines, exporters, banking, insurance, securities and other financial services firms must ensure preventative measures are in place or risk severe penalties reaching into the multimillions.

Now in its second iteration, American Conference Institute’s National Forum on OFAC Compliance and Enforcement has assembled an exceptional faculty of leading industry executives, attorneys and government officials who will analyze the latest information on:

• How OFAC measures the nature and extent of cooperation
• How to conduct a “look-back” investigation
• What OFAC guidelines reveal about the essential components of an effective sanctions compliance program
• How global companies can overcome challenges of unilateral sanctions
• Facilitation risks when working with non-US third parties
• Dealing with U.S. sanctions against Iran
• What OFAC wants to see in a license application

Contents & Contributors

OFAC’s New Enforcement Guidelines: How Financial and Non-Financial Sectors Should Prepare for Rising Compliance Expectations
Serena D. Moe, Assistant General Counsel, Citigroup (Washington, DC)
Dale C. Turza, Cadwalader, Wickersham & Taft LLP (Washington, DC)

Making the Case for Voluntary Disclosures in the New Enforcement Environment
Ronald I. Meltzer, Wilmer Cutler Pickering Hale and Dorr LLP (Washington, DC)

New Standards for an “Effective” Sanctions Compliance Program: What OFAC Guidelines Reveal About the Essential Elements
Erin L. Crockett, Director, Global Trade Compliance, Dresser Inc. (Addison, TX)
Stephanie D. Lawrence, Director, Corporate Compliance AML/OFAC, Nationwide (Columbus, OH)
Alison L. Clew – Panel Moderator, Principal, Forensic & Dispute Services, Deloitte Financial Advisory Services LLP (Boston, MA)

Facilitation: What Is It, and How to Minimize Risks
J. Daniel Chapman, Global Ethics and Compliance Director, Baker Hughes Incorporated (Houston, TX)
James D. Painter, Managing Counsel, Legal Department, The Bank of New York Mellon (Pittsburgh, PA)
Judith A. Lee - Panel Moderator, Gibson, Dunn & Crutcher LLP (Washington, DC)

Conducting a Cost Effective Internal Investigation into a Potential Sanctions Violation
William M. McGlone, Latham & Watkins LLP (Washington, DC)
Clint Stinger, Principal, Deloitte Financial Advisory Services LLP (New York, NY)

Extraterritoriality: How Global Companies Can Overcome Compliance Challenges of Unilateral U.S. Sanctions
Marynell DeVaughn, Vice President and Associate General Counsel, Alliant Techsystems Inc. (Washington, DC)
Noreen M. Fierro, Vice President, AML/FCPA Compliance Officer, Prudential Financial (Newark, NJ)
Peter L. Flanagan, Covington & Burling (Washington, DC)

Dealing with U.S. Economic Sanctions Against Iran
Scott Sullivan, Vice President & Global Trade Counsel, Flowserve Corporation (Irving, TX)
Edward L. Rubinoff, Akin Gump Strauss Hauer & Feld LLP (Washington, DC)

Structuring and Managing an Effective Screening Program and Obtaining Guidance from OFAC
Lorraine B. Lawlor, Chief, Compliance Outreach, Office of Foreign Assets Control U.S. Department of the Treasury (Washington, DC)
Elaine D. Banar, Vice President, Global Sanctions, American Express (New York, NY)
Greta Lichtenbaum, O’Melveny & Myers LLP (Washington, DC)

Conducting Due Diligence in International Transactions and Underwritings
James A. (Del) Renigar, Counsel, International Policy and Trade Regulation, The General Electric Company (Washington, DC)
Stevenson Munro, Head of AML Compliance, UBS Investment Bank (New York, NY)
Molly McLane, Global Economic Sanctions Counsel, Morgan Stanley (New York, NY)
William B. Hoffman - Panel Moderator, Davis Polk & Wardwell LLP (Washington, DC)

OFAC Licensing: Working Effectively with OFAC to Expedite the Approval Process
Timothy M. Ward, Chief Legal Officer, Hercules Group (New York, NY)
Jodi L. Kouts, Assistant Director for Licensing, Office of Foreign Assets Control, U.S. Department of Treasury (Washington, DC)
Ben H. Flowe, Jr, Berliner, Corcoran & Rowe, LLP (Washington, DC)