John Zasada, Compliance Consulting Director, Financial
Institutions Group

On April 20, 2020, the Office of Foreign Assets Control (OFAC) announced it is encouraging financial institutions affected by the COVID-19 pandemic to contact OFAC if they are going to experience delays in meeting OFAC compliance deadlines. These deadlines include the required blocking and reject reports which are to be filed within ten business days. OFAC provided the following contact information related to reporting possible delays:

OFAC also explained it will provide some leniency when it detects apparent violations by stating “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.”

For any questions regarding OFAC compliance requirements, contact Doeren Mayhew’s regulatory compliance specialists.