'One Size Fits All' Approach Doesn’t Work in OFAC Compliance Programs


Mandy Moody

ACFE Social Media Specialist


Daniel Tannebaum, CFE, Regional Head of Currency Services Compliance - Americas at Travelex and a former compliance officer with the Office of Foreign Assets Control (OFAC), refreshed ACFE Fraud Conference attendees on the importance of complying with OFAC sanctions in the breakout session, “The Most Important Regulation You’ve Never Heard Of.”

What is OFAC?

Economic sanction regulations have existed since 1812. The Office of Foreign Assets Control (OFAC) was first organized in the 1940s, and administers and enforces economic and trade sanctions against target hostile governments, individuals, entities and practices. The office has jurisdiction over American citizens and permanent resident aliens located anywhere in the world, as well as any individual, regardless of citizenship, which is physically located anywhere in the United States. In other words, this small acronym means big compliance issues for businesses potentially (or even mistakenly) interacting, or preferably not interacting, with governments like Cuba, Iran and Libya, terrorists, drug traffickers or businesses involved with proliferating weapons of mass destruction.

“OFAC is not a regulator, but rather an enforcement agency; when they turn up at your office, it’s usually too late,” Tannebaum said. “It is unlike any other regulatory agency in the world. Its sole mission is economic sanctions.”

He compared OFAC to the Bank Secrecy Act (BSA), advising strict liability compliance versus taking a risk-based approach. Federal regulators and compliance professionals like Tannebaum are dedicated to monitoring and avoiding interaction with those businesses and individuals on the Specially Designated Nationals (SDN) and Blocked Persons List, and those part of the regime based sanctions programs.

Read the full article here.