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OFAC Essentials

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In order to meet the need for more in-depth training on OFAC Essentials and mitigate the risk of costly sanctions violations, we have developed an online sanctions training program, which teaches vital OFAC principles and background all OFAC sanctions compliance staff should understand.

Target audience

OFAC/Sanctions Compliance Officers

OFAC Analysts

OFAC investigators

General Counsels

OFAC Compliance Managers

OFAC Testing Analysts

What is it?

This is a 7-part course, consisting of approximately 7 training hours, across 4 weeks. The course is delivered in an online format.

Self-paced e-learning course

Reading Assignment

Live Virtual Classroom

Reading Assignment

Live Virtual Classroom 2

Case Study

Online Quiz

What Participants will get

At the end of 4 weeks, participants who successfully completed the program receive:

Certificate of Completion: Upon passing the assessment, participants will receive an electronic Certificate which denotes the completion of the course.

7 ACSS Credits (you must complete the whole course)

System Requirements

OFAC Foundations is compatible with most operating systems and browsers to make it easy for everyone to participate. The course uses

Goto Training from Citrix

E-learning (Adobe Captivate or similar tool)

Litmos or other Learning Management System (LMS)

Upcoming Virtual Session

2022 Fall Session

  • Sept 7, 2022 – Course becomes available
  • Sept 14, 2022 – 1st Virtual Class (12:00–1:30 ET)
  • Sept 21, 2022 – 2nd Virtual Class (12:00–1:30 ET)

Cost

ACSS Members

$495

REGISTER NOW

Non-ACSS Members

$595

REGISTER NOW

If you have multiple team members who can benefit from this program or wish to talk about enterprise packages, please contact for pricing and more information: helpdesk@sanctionsassociation.org or call +1-305-433-7187

How it is structured?

PART 1: Self-Paced E-Learning Course (30 minutes)

This is a 30-minute self-paced e-learning course on the ACSS Learning Management System (LMS), which covers OFAC Essentials and Background:

  • What is OFAC and mission
  • History
  • OFAC sanctions and their objectives
  • Different types of OFAC sanctions regimes
  • Who must comply?
  • Fines
  • “OFAC online” – Where to find things on the OFAC website
PART 3: Virtual Classroom #1: Legal Authorities and How OFAC Works (90 minutes)

Interactive live virtual classroom (webinar with interaction, such as case studies, Q&A sessions, audience polls and practice questions.)

A Walking Tour Through main OFAC legal authorities

  • IEEPA – what is it, when enacted, where to be found, what does it do?
  • TWEA – what is it, when enacted, where to be found, what does it do?
  • Anti-Terrorism and Effective Death Penalty Act, Foreign Narcotics Kingpin Designation Act others
  • Presidential Executive Orders
  • OFAC Regulations codified at 31 CFR Ch V–main clauses
  • Short Exercise/case study/Practice questions

Categories, Principles and Core ConceptsUsed Throughout Sanctions Regimes Administered by OFAC

  • Categories: Comprehensive, vs limited, country regimes, list-based regimes, sectoral, extraterritorial, and other categories of regimes. Provide examples.
  • High level principles and core concepts or core prohibitions under Main OFAC administered Sanctions Regimes.
  • Important concepts or terms used throughout a number of OFAC administered sanctions programs (e.g. facilitation)
  • Short Exercise/case study/Practice questions

Overview of OFAC Organizational structure – who does what?

  • Sanctions Policymaking &Coordination
  • OFAC Compliance – how does OFAC assist with compliance efforts?
  • OFAC Licensing Department – How does this department work?
  • OFAC Global Targeting& Investigations
  • Short Exercise/case study/Practice questions

Q&A with audience

PART 5: Virtual Classroom #2: OFAC Risk Management and Enforcement (90 minutes)

Interactive live virtual classroom (webinar with interaction, such as case studies, Q&A sessions, audience polls and practice questions.)

Recognizing OFAC Sanctions Risks: Sound OFAC Risk Assessment

  • Inherent and residual risk.
  • How to structure a sound risk assessment and calculate risks?

OFAC Compliance Program – Control Basics

  • OFAC Policy: What should it contain?
  • Designated persons, prohibitions
  • OFAC Training: Who, what, where, when and why?
  • OFAC Independent Review
  • Short Exercise/case study/Practice questions

Customer Due Diligence and Screening

  • Prohibited Transactions
  • Due Diligence and how the 50% rule works
  • List matching/screening and assessing OFAC name matches
  • Voluntary disclosures: how to go about it?
  • Blocking and Rejecting and Reporting to OFAC
  • Releasing blocked funds
  • Short exercise /case study/Practice questions

OFAC Reporting Requirements

  • Report of Blocked and Rejected Transactions Form: Form to Use, How to Fill Out?
  • Annual Report of Blocked Property Form
  • Short Exercise/case study/Practice questions

OFAC Licenses

  • When you need a license
  • How to apply, forms to use? Where to submit
  • How long does it take?
  • Best practices and helpful tips

OFAC Enforcement:

  • OFAC Enforcement Guidelines
  • OFAC’s Administrative Subpoena (31 C.F.R. § 501.602): Process and Response.
  • Consequences of non-compliance: Penalties, and other types of actions
  • Interaction with other agencies
  • Short exercise/case study/practice questions

Q&Awith Audience

Part 2: Reading Assignment (60 minutes)

Two reading assignments containing key terms and definitions participants need to read to prepare for Virtual Class 1.

PART 4: Reading Assignment (30 minutes)

“Reading Assignment 2” containing key terms and definitions participants need to read to prepare for Virtual Class 2.

PART 6: Case Study (30 minutes)

Posting of Message or Question on ACSS Forum (15 minutes)

PART 7: Final Assessment (60 minutes)

Online Quiz: This is a multiple question quiz in multiple choice format.

Speaker Faculty

Scott Nance

Scott Nance from Langley Compliance Consulting. Based in DC. He is an attorney specializing in economic sanctions and anti-money laundering. He helps companies comply with economic sanctions, answering their questions about what they can and should do. Uniquely, he has worked inside several large European banks, and was the Global Head of Sanctions Compliance for ING in Amsterdam, he has also done extensive work in the fields of international trade and economic policy, and have had the opportunity to advise a number of governments in Africa and Asia on trade policy. He teaches International Trade Law and Investment at William & Mary Law School and has lectured on economic development and international trade at the University of Virginia. Scott is a member of the ACSS editorial Task force and the ACSS Certification Task Force.

Erich Ferrari

Erich Ferrari is the Principal of Ferrari & Associates in Washington, D.C.  Mr. Ferrari represents financial institutions, multi-national corporations, and individuals in matters involving U.S. economic sanctions administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).  Much of his work focuses on advising clients on how to navigate and comply with authorities administered by OFAC, seek license authorizations from OFAC for clients seeking to engage in otherwise prohibited transactions, and representing parties in pending OFAC enforcement matters.  Mr. Ferrari has written and lectured widely on all aspects of U.S. sanctions law.  He writes extensively on such matters on his blog: www.sanctionlaw.com.  Mr. Ferrari graduated from St. Mary’s University School of Law in 2006 and was admitted to the District of Columbia Bar in 2007.

Daniel Tannebaum

Daniel is a Partner and member of the Americas Risk and Public Policy Practice at Oliver Wyman. He leads the Anti-Financial Crime Practice for the Americas and serves as the firm’s Global Head of Sanctions.
Dan provides AML and Sanctions regulatory crisis management support. He also provides strategic AML and Sanctions Compliance Program support to a variety of clients. Prior to joining Oliver Wyman, he was a Partner at a global consulting firm where he supported the Global AML and Sanctions Remediation for several G-SIFIs under investigation or subject to enforcement actions.

Previously Dan served as the Head of Compliance for the Americas and Global Sanctions Champion at Travelex. Before joining Travelex, Dan was the OFAC Compliance Coordinator for the Federal Reserve Bank of New York, where he advised on OFAC issues.

Dan began his career in Compliance when he served as a Compliance Officer with OFAC.