Posted on May 02,2022 in Firm News

All participants in the global supply chain ecosystem face the risk of noncompliance with sanctions issued by the U.S. Treasury's Office of Foreign Asset Control (“OFAC”). These participants include not only sellers and buyers engaged in international trade, and but also include the array of service providers that support international trade including banks, factors and other non - bank trade finance providers, trade credit insurers and freight forwarders and trade logistic companies. Strict observance of OFAC sanctions requires a robust and vigilant compliance program.

However, managing a compliance program that dynamically responds to evolving business practices and evolving OFAC sanction requirements is very challenging. The failure to meet such challenges can expose companies to significant financial penalties and reputational damages.

The challenges of OFAC compliance, and the risks of non - compliance are sharply on display in the Enforcement Release issued by the OFAC on April 25, 2022 (“Enforcement Release”). In this Enforcement Release OFAC announced a $6,131,855 settlement entered into with the Australian based freight forwarding company, Toll Holdings Limited (“Toll”), regarding potential civil liability arising from 2,958 apparent violations of multiple OFAC sanctions programs.

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