OFAC Acknowledges Possible Compliance Delays Due to the Pandemic

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:

• Blocking / Reject Reports: Call 202-622-2490 or 800-540-6322, or email ofac_feedback@treasury.gov. 
• Administrative Subpoenas: Please contact the case officer identified on the particular administrative subpoena.
• License Reports: Call 202-622-2480 or email ofac_feedback@treasury.gov​. You may also reach out through the online licensing portal.
• Requests for Reconsideration of a Listing as an SDN (Petitions):  Please email reconsideration@treasury.gov. 

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.