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Office of Foreign Assets Control Risk Assessment

Gain insight into how to evaluate risks posed by parties, transactions, and entire lines of 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 (1) how individual departments and product lines might be exposed to sanctions risk, (2) how to identify high-risk transactions and parties, and (3) 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's sanctions now 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.
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview: What Is an OFAC Risk Assessment?
  • Several Definitions
  • Scope of Review
OFAC Risk Assessment Process: How to
  • Identify the Parties, Geographic Regions, and Products/Services Involved
  • Identify a Potential Sanctions Nexus
  • Identify the Relevant Rules (Statutes, Regulations, Guidance, Legal Advice, or Internal Policies)
  • Evaluate the Risk Posed by a Sanctions Nexus
  • Identify and Implement Possible Controls
  • Determine Appropriate Next Steps Based on Risks Posed and Risk Appetite
How to Conduct Risk Assessments of International Funds Transfers
  • Commercial Transfers
  • Personal Transfers
  • Informational Constraints
How to Conduct Risk Assessments for New Customers
  • Nonresident Aliens
  • International Organizations
  • Partner/Customer Intake Forms and Profiles
How to Conduct Risk Assessments for Commercial Letters of Credit
  • International Commercial Shipments
How to Conduct Risk Assessments for Overseas Branches and Subsidiaries
  • High Enforcement Priority
  • Foreign Partner/Customer Affiliates
Case Studies
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Oliver Krischik

Oliver Krischik

GKG Law, P.C.

  • Trade law attorney who focuses on representing businesses, individuals, and nonprofit organizations with issues surrounding economic sanctions, export controls, and financial regulations
  • Counsels his clients on trade compliance, licensing, and enforcement matters related to the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Dept. of the Treasury’s Financial Crimes Enforcement Network (FinCEN), the U.S. Dept. of Commerce’s Bureau of Industry & Security (BIS), the U.S. Dept. of Commerce’s Office of Antiboycott Compliance (OAC), and the U.S. Dept. of State’s Directorate of Defense Trade Controls (DDTC)
  • Assists the firm’s Association Practice Group in assessing the European Union’s General Data Protection Regulation (GDPR) developments
  • Assists his clients with all aspects of U.S. economic sanctions and export controls compliance
  • Frequent author and speaker on various topics and selected by Super Lawyers as a Rising Star
  • J.D. degree, Georgetown University; B.A. degree, Washington and Lee University; B.A. degree, Georgetown University
  • Can be contacted at 202-342-5266 or [email protected]
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Product ID: 407076
Published 2019
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