Drug Kingpins and Blacklists: Compliance Issues with US Economic Sanctions: Part 2

The proliferation of sanctions programmes over time, each with its own set of regulations and its own peculiar blacklist, makes it more difficult for OFAC to administer the controls in a smooth, consistent and efficient manner. Additionally, unlike other agencies involved in international trade — such as the Commerce Department's BXA, or the State Department's DTC — OFAC has been slow to develop a cooperative relationship with those who must comply with its regulations. While OFAC's singular focus on economic and financial sanctions has enabled it to avoid some of the problems the Commerce Department sometimes experiences as a result of its dual missions of both promoting and controlling trade, it has also fostered a more adversarial relationship with the trading community. As OFAC has focused on each sanctions programme individually, rather than as part of a comprehensive system of controls, it has tended to be insensitive to the needs of those who must integrate its diverse regulatory requirements into an overall business compliance process.