OFAC Compliance in Practice: Screening, Licensing and Penalties

Introduction

Understanding the OFAC framework is only the beginning.Effective compliance requires operationalising that knowledge — buildingscreening programmes that work, navigating the licensing process, and knowinghow to respond when something goes wrong. This intermediate course moves beyondtheory to focus on the practical mechanics of OFAC compliance, drawing on realenforcement cases and operational best practices. It is designed for complianceprofessionals who already have a basic understanding of US sanctions and wantto sharpen their operational skills.

Who ThisCourse Is For

This course is aimed at compliance officers, sanctionsanalysts, legal counsel, and operations managers at financial institutions,trading companies, and other organisations with significant OFAC exposure.Participants should have a foundational knowledge of US sanctions, such as thatcovered in OFAC 101.

WhatYou'll Learn

•      How to design and operate an effective OFAC screeningprogramme

•      How to manage false positives and conductinvestigations

•      How to apply for OFAC specific licences and managegeneral licence conditions

•      How to handle blocked and rejected transactions

•      How to conduct a voluntary self-disclosure to OFAC

•      How OFAC calculates penalties and what factors affectenforcement outcomes

•      How to apply OFAC's Framework for ComplianceCommitments to your programme

CourseStructure

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

Duration: 2 hours

Level: Intermediate

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. OFAC's Compliance Framework

•      OFAC's 2019 Framework for Compliance Commitments

•      The five essential components of an OFAC complianceprogramme

•      Management commitment and senior-level accountability

•      Risk assessment: identifying OFAC exposure acrossbusiness lines

2. Screening in Practice

•      What to screen: customers, counterparties,transactions, and vessels

•      SDN list, FSE list, SSI list, and CAATSA designations

•      Fuzzy matching and name variation challenges

•      Managing false positives: investigation and escalation

•      Ongoing monitoring vs point-in-time screening

3. Licensing

•      Identifying and applying general licences correctly

•      Specific licence applications: preparing a strongsubmission

•      Timelines and OFAC response expectations

•      Compliance conditions attached to licences

4. Blocking and RejectingTransactions

•      When to block vs when to reject a transaction

•      Blocking reports: what to file and when

•      Annual reports on blocked property

•      Handling blocked funds and property

5. Enforcement andSelf-Disclosure

•      How OFAC calculates civil monetary penalties

•      Aggravating and mitigating factors in enforcement

•      Voluntary self-disclosure: procedure and benefits

•      Case studies: lessons from major OFAC enforcementactions

Level
Intermediate
120min
Written by
Alexander Witt
Founder of Sanctions Center

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