Obama Sanction-o-Rama, Part 2: Guidance on Compliance Services

As part of its last minute house-cleaning before Inauguration Day, OFAC explained in a guidance document that the following non-comprehensive list of compliance services may be provided to persons who are not sanctioned themselves:

 

  • Providing information or guidance regarding the requirements ofU.S. sanctions laws administered by OFAC, including statutes, regulations, and Executive orders. For example, a U.S. person may present on the topic of U.S. sanctions laws in a non- sanctioned third country, and a U.S. person compliance officer working at a covered person entity may advise covered person employees and covered person business partners on the requirements of U.S. sanctions laws.

  • Opining on the legality of specific transactions under U.S. sanctions laws regardless of whether it would be prohibited for a U.S. person to engage in those transactions. U.S. persons may solicit information from covered persons and conduct research to make a determination as to the legality of transactions under U.S. sanctions laws provided there is no importation of services where the importation of services is prohibited by any part of 31 C.F.R. chapter V. 

Links:

OFAC Notice

Compliance Services Guidance

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