OFAC Encourages Industry Communication During COVID-19 Pandemic

The Treasury’s Office of Foreign Assets Control is encouraging industry impacted by the COVID-19 pandemic to reach out to OFAC if the agency's regulations are delaying industry's ability to “meet deadlines,” OFAC said in an April 20 notice. This includes industry’s ability to file blocking and reject reports (see 2002200057), responses to administrative subpoenas, reports required by general or specific licenses or “any other required reports or submissions.” OFAC also asked industry to submit self-disclosures to OFACdisclosures@treasury.gov instead of physical submissions.

The agency added that it “understands” the pandemic “can cause technical and resource challenges for organizations.” If a company “chooses … to account for such challenges by temporarily reallocating sanctions compliance resources,” OFAC “will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.” The agency said it will address those situations on a case-by-case basis.