The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) administers the nation’s sanctions programs through the imposition of both criminal and civil penalities and the blocking of property and interests under the jurisdiction of the United States.

The regulations and procedures for complying with these sanctions are complex and tedious. Individuals who run afoul of OFAC administered sanctions, may have no idea that they or their business has done anything wrong until after OFAC freezes their assets, fines them, or worst of all, they are arrested.

Given the broad reach of these regulations, individuals and businesses can be targeted by mere association with others who have been blacklisted by OFAC. Whether you are a landlord renting property to someone who has been placed on OFAC’s Specially Designated National (“SDN”) List, a graduate student seeking to travel to Cuba, or a foreign lawyer providing legal services to an SDN, you are at risk.

If you are a U.S. person, or own property and/or interests under the jurisdiction of the United States, and have dealings with anyone from the following countries:

1. The Balkans
2. Belarus
3. Burma
4. Cote d’Ivoire (Ivory Coast)
5. Cuba
6. Democratic Republic of the Congo
7. Iran
8. Iraq
9. Former Liberian Regime of Charles Taylor
10. North Korea
11. Sudan
12. Syria
13. Zimbabwe

or are possibly associated with individuals or entities engaged in terrorism, diamond trading, narcotics trafficking, proliferation of Weapons of Mass Destruction, or involved in the undermining of the sovereignty of Lebanon, you may be at risk.

Before OFAC gets to you, find out how to comply with the sanctions and protect yourself from possible penalty. Successful compliance with the sanctions can be achieved, if knowledgable and experienced counsel is retained.

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