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Affiliate/NCBFAA Webinars

OFAC Sanctions Compliance for Freight Forwarders and Customs Brokers

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces U.S. economic sanctions programs. U.S. economic sanctions differ from many other regulatory regimes, however, in the sense that they are a strict liability regime that can prohibit virtually all activity related to sanctions persons, territories, economic sectors, vessels, aircraft, and governments. These prohibitions also apply to customs brokers and freight forwarders and the sanctions nexus may not always be obvious. On May 2, 2019, OFAC issued a framework for Sanctions Compliance Programs (SCPs) that must be followed for companies to obtain credit for the mitigating factor of maintaining an SCP. This webinar will examine how sanctions may impact customs brokers and freight forwarders, and outline the elements of a SCP needed to obtain “mitigating factor” credit.