The Office of Foreign Assets Control (OFAC) Encourages Persons to Communicate OFAC Compliance Concerns Related to the Coronavirus Disease 2019 (COVID-19)
On March 13, 2020, President Trump declared a National Emergency in response to COVID-19. On April 16, 2020, OFAC published a fact sheet that summarizes existing exemptions and authorizations to provide humanitarian assistance in the context of the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs.
Separately, OFAC encourages persons, including financial institutions and other businesses, affected by the COVID-19 global pandemic to contact OFAC as soon as practicable if the person believes it may experience delays in its ability to meet deadlines associated with regulatory requirements administered by OFAC. This includes requirements related to filing blocking and reject reports within ten business days as required by 31 C.F.R. §§ 501.603 and 501.604, responses to administrative subpoenas issued pursuant to § 501.602, reports required by general or specific licenses, or any other required reports or submissions.
The appropriate OFAC contact information is below:
• Administrative Subpoenas: Please contact the case officer identified on the particular administrative subpoena.
• Requests for Reconsideration of a Listing as an SDN (Petitions): Please contact firstname.lastname@example.org
In addition, OFAC encourages persons to submit self-disclosures to the following e-mail account rather than through physical mail: OFACdisclosures@treasury.gov. Please also refer to OFAC’s Data Delivery Standards for detailed electronic submission guidance.
OFAC understands that the COVID-19 pandemic can cause technical and resource challenges for organizations. As OFAC has articulated in both its Economic Sanctions Enforcement Guidelines (31 C.F.R. part 501 Appendix A) and its Framework for Compliance Commitments, the agency supports a risk-based approach to sanctions compliance. Accordingly, if a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part of its risk-based approach to sanctions compliance, to account for such challenges by temporarily reallocating sanctions compliance resources consistent with that approach, OFAC will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period. OFAC will address these issues on a case-by-case basis.