Introduction: The Office of Foreign Assets Control

The Office of Foreign Assets Control (OFAC) is the government agency charged with implementing federal economic sanctions on other countries. OFAC’s regulations detail which accounts you should “block” (i.e., freeze); which transactions you should refuse; what records you must maintain; and so forth.

This section will summarize these requirements. It will start with a general description of how you determine that a transaction is subject to OFAC rules and what you should do when you make that determination. The section will then discuss “licenses,” which are issued by OFAC and whose function is to allow transactions otherwise prohibited by the rules. We will then summarize OFAC’s suggestions with respect to financial institution compliance programs. Next will be the civil and criminal penalties for not complying. Finally, we will list OFAC record-keeping and reporting requirements.