Day 1 - Wednesday, November 6, 2019

Registration and Continental Breakfast
Opening Remarks
Deep Dive into U.S. Primary and Secondary Sanctions

  • Understanding the roles of the primary agencies: OFAC, BIS, and State
  • Key Definitions: OFAC, US Person, US Nexus, SDN, and sanctioned countries
  • Differences between statues, regulations, directives, formal guidance, interpretations, and FAQ’s
  • Types of sanctions – embargos, prohibited parties/activities, secondary sanctions
  • List based sanctions programs

OFAC Expectations for Your Sanctions Compliance Program and Key Elements of an Effective Plan

  • Understanding your risk profile
  • Strengthening your internal controls
  • Components of sanctions training program
  • Use of audit to test your compliance program
  • How to gain senior management buy-on

Networking Break
How to Perform Sanctions Screening and Tools Available to Assist You

  • Understanding OFAC lists
  • How to use BIS Entity List and BIS unverified lists
  • How to clear false positives
  • Blocked interest vs. impermissible transaction
  • Potential of artificial intelligence to strengthen

Recent Enforcement Trends and Current Regulatory Landscape

  • Lessons learned from recent enforcement action
  • Possible OFAC investigative actions
  • How to respond to an OFAC investigation
  • New rule on rejected transactions

Licensing: How Statutory Exemption, General Licenses and Specific Licenses Allow for Other Prohibited Activity

  • General vs. Specific licenses
  • Interactions with OFAC to expedite licensing process
  • Exemption for humanitarian purposes
  • Working with OFAC for voluntary disclosures

Networking Break
Drill Down into Country Specific Sanctions Considerations

  • Rapidly changing Russia sanctions, 50% rule and the role of CATSA
  • What is the EU Blocking Statute and how is it applied
  • Staying compliant with latest sanctions on Venezuela
  • How to deal with foreign subsidiaries of US companies

Intersection of Export Controls and Sanctions
Boot Camp Ends

Fundamentals of Russia Sanctions: Staying Compliant with Primary and Secondary Sanctions Restrictions

Nov 7, 2019 9:00am - 12:30pm


What is it about?

This in-depth workshop is much more than a basic review of Russia Sanctions. This interactive workshop will provide timely guidance on these complex sanctions through interactive hypotheticals and will cover the following topics:

  • Overview of the latest sanctions’ restrictions and impact of new Russian counter sanctions
  • Update on OFAC guidance for licensing
  • Practical considerations for screening, ownership and control
  • Case studies on how to apply the 50% rule
  • Strategies to mitigate secondary sanctions risks

OFAC Compliance Program Best Practices

Nov 7, 2019 1:30pm - 5:00pm


What is it about?

This interactive workshop is designed to provide in-depth coverage of sanctions compliance programs from A to Z. This program will focus on the recent OFAC Framework for OFAC Compliance Commitments and will focus on following topics:

  • OFAC expectations
  • Managing your risk profile
  • How to conduct sanctions training
  • Timing and scope of sanctions audits
  • Compliance best practices