OFAC 101: Understanding US Sanctions Programmes

Introduction

The Office of Foreign Assets Control (OFAC) administers themost far-reaching and frequently enforced sanctions regime in the world. USsanctions have extraterritorial reach that affects non-US companies doingbusiness in US dollars, with US counterparties, or involving US-origin goods.This introductory course provides a clear overview of the OFAC sanctionsframework, the key programmes, and what compliance looks like in practice. Itis the essential starting point for anyone seeking to understand US sanctionsobligations.

Who ThisCourse Is For

This course is suitable for compliance, legal, and operationsprofessionals at banks, financial institutions, trading companies, and anyorganisation exposed to US sanctions through dollar-denominated transactions, UScounterparties, or US-origin goods. No prior knowledge of US sanctions isrequired.

WhatYou'll Learn

•      What OFAC is and how the US sanctions framework isstructured

•      The key US sanctions programmes: Iran, Russia, Cuba,North Korea, Syria, and others

•      The difference between comprehensive sanctions andtargeted designations

•      How to use the Specially Designated Nationals (SDN)list and other OFAC lists

•      What conduct is prohibited under US sanctions

•      Licensing: when authorisation is available and how toapply

•      Penalties and enforcement: the consequences of OFACviolations

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 1 hour

Level: Beginner

Assessment: Noformal assessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

Course Content

1. The OFAC Framework

•      OFAC's legal authority: IEEPA, TWEA, and UNParticipation Act

•      The role of the President: executive orders andnational emergencies

•      OFAC's relationship with the State Department and BIS

•      How OFAC sanctions programmes are created and updated

2. Key US Sanctions Programmes

•      Comprehensive programmes: Cuba, Iran, North Korea,Syria

•      Russia and Ukraine-related sanctions

•      Counter-terrorism and counter-proliferation programmes

•      Narcotics and transnational crime-related designations

•      How to find and monitor active OFAC programmes

3. Prohibited Transactions andObligations

•      What is a 'prohibited transaction' under US sanctions?

•      The SDN list and other OFAC designation lists

•      The 50% rule: ownership and control by sanctionedparties

•      US persons, US dollars, and US-nexus transactions

•      Blocking vs rejecting: different obligations fordifferent situations

4. Licences and Authorisations

•      General licences: blanket authorisations for commonactivities

•      Specific licences: individual applications to OFAC

•      Humanitarian and civil society exceptions

•      FAQs and guidance documents as compliance tools

5. Enforcement and Penalties

•      Civil vs criminal enforcement

•      Voluntary self-disclosure: benefits and process

•      Egregious vs non-egregious violations

•      Case example: a significant OFAC enforcement action

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