Chicago Economic Sanctions Boot Camp

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

Lunch

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