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 screening

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