High OFAC Advisory Output to Continue, Firm Says

The Office of Foreign Assets Control has substantially increased its sanctions advisory output in recent years, a trend likely to continue, according to Castellum, a technology company that operates an automated compliance screening service. OFAC issued 10 sanctions advisories in the past two years, including four this year, compared with nine advisories in the previous eight years, the company said Nov. 15. “This emphasis on advisories, across both democratic and republican administrations, shows that this public-facing tool is here to stay and will be used more frequently,” Castellum said. The company also said the increased number of sanctions could allow OFAC to justify larger penalties for sanctions violations, “because those that are subject to enforcement actions will have had significant public warning.” OFAC most recently issued a guidance to help the virtual currency industry navigate U.S. sanctions (see 2110150069).