The purpose of this paper is to highlight some of the most significant US sanctions risks faced by persons that operate in the securities and investment marketplace, in order to encourage firms to maintain comprehensive, risk‐based compliance controls that will strengthen their ability to comply with US sanctions regulations.
The paper begins with a brief overview of the sanctions programs administered by the US Treasury Department's Office of Foreign Assets Control (OFAC), followed by examples of potential sanctions violations that emphasize the risks and challenges faced by the securities and investment sector with respect to sanctions. Finally, the paper describes how firms can develop measures intended to mitigate their OFAC risk and prevent the potentially costly monetary penalties associated with violations of US sanctions regulations.
The nature of the securities and investment sector can make identifying the often indirect sanctions implications of engaging in certain activity a challenging task; however, a well thought out, responsibly implemented OFAC compliance program can help mitigate sanctions risks in an effective manner.
The paper provides insight regarding OFAC compliance in the securities and investment sector directly from the government agency responsible for administering and enforcing US sanctions.
