Companies and individuals subject to US law must comply with an extensive regime of economic sanctions against nations, organizations, and individuals. The US government imposes these sanctions in support of foreign policy goals. Compliance can be complex and burdensome.
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OFAC enforces sanctions imposed by the US government, and the penalties for violating them can be serious or even catastrophic. The authorities even impose criminal penalties against individuals and companies from time to time. The rules are constantly changing, and their interpretation and enforcement involve a significant amount of discretion.
At Sequoia Legal, we understand the sanctions regime in great detail, and we make sure to keep up with a rapidly changing regulatory environment. Our primary goal is to help you head off trouble before it arises, and our services focus heavily on employee education.
We perform a variety of services that help you comply with OFAC restrictions, and we minimize the time, expense, and trouble involved if you do find yourself running afoul of any regulations.
We can minimize the impact of OFAC restrictions on your company by helping you obtain both general licenses and specific licenses. General licenses are loopholes within the regulations themselves, while specific licenses require special permission from OFAC.
The SDN List, officially known as the Specially Designated Nationals and Blocked Persons List, is a list that you don’t want to be on. It’s also a list of companies and individuals that you could get into trouble with for doing business. It is possible to be removed from this list, and we have arranged for removals before.
Banks will freeze assets, usually, money, if they believe that the blocked assets are part of a transaction that violates OFAC sanctions. Sometimes these transactions are blocked in error. Consequently, it is often possible for us to unblock these transactions.
OFAC may issue you a subpoena requiring you to provide information about a particular transaction. This can be a dangerous moment for you, and you must respond in an appropriate manner. We can help you do that.
You cannot comply with the regulation if you do not understand its requirements. It would be a shame for your company to be sanctioned merely for lack of knowledge of what the law requires. We can counsel you on compliance matters.
You might face OFAC litigation due to:
We can help you fight back.
If your company frequently engages in international trade, it is easy to inadvertently violate OFAC restrictions. In fact, an internal audit might reveal a violation that occurred months or even years in the past. In these cases, it is sometimes best to report your own company to OFAC to receive a lighter penalty. If you decide to do this, we can help you do it right.
OFAC has targeted the following nations for sanctions under the authority of the United States government:
Remember that this list could change at any moment. Remember also that it is not only nations that are subject to sanctions, but also certain individual citizens or nationals of these nations, as well as companies and organizations affiliated with these nations. These sanctions may apply to your company as well, by preventing you from doing business with any of these parties.
Because of the importance of international trade to the U.S. economy, our firm serves a wide variety of clients operating in virtually every sector of the economy. These firms have worked with OFAC Iran lawyers, OFAC lawyers for Cuba transactions, and Russian sanctions law firms, among others, before finally coming to us. The types of companies we work with include:
This is only an abbreviated list of the types of companies we work with.
International trade law is one of the most complex areas of law in existence. Our OFAC sanction attorneys are qualified, knowledgeable, and experienced. We offer decades of combined experience in successfully resolving the kinds of problems you are likely to need help with. We have successfully resolved OFAC problems for numerous clients working in virtually every sector of the economy.
There are five major types of OFAC sanctions:
Each of these sanctions targets different parties for different purposes.
The penalties for OFAC violations vary widely. They can include:
Some firms have faced aggregate fines of over $1 billion.
If your potential customer shows up on the SDN list, you must conduct an investigation. It could be meaningless. For example, it could be as simple as a coincidence between your customer’s name and the name of a ship that is on the list. If the hit is legitimate, however, you need to call the OFAC hotline.
If OFAC or a bank blocks or freezes a transaction, you need to file an unblocking application. This is a complex and burdensome process with no guarantee of success. We can help.
If you require the services of an OFAC compliance law firm, Sequoia Legal stands ready to assist. Visit our contact page or call 303-476-2851 for a consultation.
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Teresa M.
We ran into a hit on the SDN list. It turned out to be a case of mistaken identity, and Sequoia Legal helped us resolve the issue in a quick and cost-efficient manner. Very professional and knowledgeable.
Mike C.
A couple of years ago, our company had no compliance program to speak of, and we were barely aware of the existence of OFAC regulations. Sequoia Legal helped us get our house in order, and we have had no problems since then.
Jacqueline K.
We contacted Sequoia Law after an internal audit revealed that our company had inadvertently committed two substantial OFAC violations over the past two years. We chose the path of voluntary disclosure to OFAC and received lenient penalties. Many thanks to Sequoia for their adroit handling of the matter.
