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Office of Foreign Assets Control Risk Assessment


Learn effective techniques for managing working capital in your business.

On May 2, 2019, the Office of Foreign Assets Control (OFAC) released new guidance stating that holistic sanctions risk assessments must be a part of a company's Sanctions Compliance Program (SCP) for the SCP to qualify as a mitigating factor in enforcement decisions. These risk assessments require banks and businesses to understand how individual departments and product lines might be exposed to sanctions risk, how to identify high-risk transactions and parties, and which of these risks can be addressed with appropriate controls. Yet, many banks and businesses continue to rely on processes that do not reflect the diverse range of sanctions programs and measures in place today.
For example, OFAC now sanctions country-based embargoes, lists of prohibited parties, sectoral sanctions with transaction-specific restrictions, as well as numerous general licenses that authorize certain activity with a sanctions nexus. This topic helps persons at the C-Suite, department management, and transaction review levels understand how to evaluate risks posed by parties, transactions, and entire lines of business. In addition, the material explains how companies can identify measures to mitigate sanctions risk at systemic and transaction-specific levels.
Moreover, this topic will cover specific issues concerning financial transactions with a historically high risk of sanctions exposure. As OFAC continues to raise its standards for compliance practices, this information is critical for businesses to ensure that their SCP meets the new requirements and mitigates unnecessary risks across their organizations.



Oliver Krischik

Oliver Krischik

GKG Law, P.C.

  • Partner, GKG Law, P.C.
  • Practice areas include OFAC economic sanctions, export controls, anti-money laundering, transportation, trade and logistics, international trade compliance, banking and financial fraud, trade and professional associations, and data privacy
  • Currently advises all GKG Law attorneys on sanctions issues pertaining to various practices at the firm
  • Super Lawyers Rising Star – Top Rated Administrative Law Attorney in Washington, DC (2019-Present); and Best Lawyers Ones to Watch in Washington, D.C. Transportation Law – 2021-Present
  • Often quoted in national publications, including The New York Times, on OFAC sanctions-related topics, issues, and breaking news
  • Featured speaker on webinar and seminar topics, including international trade, transportation, and issues surrounding sanctions and immigration; published author on a range of legal issues, including OFAC sanctions, federal financial regulations, export controls, data privacy, and the GDPR
  • Served as co-chair of the Economic Sanctions Practice Group at a mid-size firm prior to joining GKG Law, P.C.
  • American Bar Association Section of International Law’s Export Controls and Economic Sanctions Committee and Steering Group Member
  • Admissions: Virginia and the District of Columbia
  • J.D. degree, Georgetown University Law Center
  • Can be contacted at [email protected] or 202-342-5266

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