ABA - OFAC Facilitation: Know It When You See It?
November 8, 2012
As economic sanctions administered by the Treasury Department's Office of Foreign Assets Control ("OFAC") are increasingly recognized as a critical tool for effecting U.S. foreign policy interests, important questions remain as to the reach and scope of OFAC's regulations and enforcement policy. In particular, the prohibitions against U.S. "facilitation" of foreign person's transactions involving sanction targets prompt the question of what is permissible in an environment of scant regulatory guidance and myriad compliance risks.
This program examines the OFAC facilitation prohibitions from two fresh perspectives. First, following a brief review of the key regulatory provisions, noted legal scholars will engage in a timely discussion on Constitutional curbs and other potential limitations on facilitation, with a focus on recent jurisprudential trends. Second, a panel of OFAC "alumni" will provide insights as former government regulators and current counsel to multinational companies striving to operate and comply in the face of this regulatory uncertainty.
Cari Stinebower is a participant on a panel, "OFAC Alumni Speak."
Crowell & Moring Participant(s):
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