By: Lisa M. Palluconi, Acting Director, Office of Foreign Assets Control, U.S. Department of the Treasury
Economic and trade sanctions continue to be an important tool to support the United States’ foreign policy goals and to address pressing national security concerns. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces sanctions, and the private sector acts as a critical partner in ensuring the success of our mission.
OFAC is committed to modernizing its infrastructure and approaches to engaging with stakeholders to ensure sanctions are easily understood and enforceable — a key recommendation highlighted in Treasury’s 2021 Sanctions Review that OFAC is working to implement.
For example, we regularly meet with companies, organizations, and civil society groups impacted by our sanctions to better understand the implementation issues they face and their best practices for sanctions compliance. This valuable feedback from the public has informed several recent OFAC initiatives aimed at making our sanctions easier to implement.
You may already be aware of some of these efforts, such as the launch of OFAC’s new website and the introduction of OFAC’s video series. I want to highlight some other important initiatives this year.
General Frequently Asked Questions (FAQs) Update
To ensure our guidance remains up to date and relevant for the public, OFAC is updating many of its FAQs on general sanctions questions and issues. These FAQs are often our most viewed guidance, as they deal with basic principles of sanctions implementation. The first installment of updated FAQs is available now (FAQs 1, 3, 4, 6, 7, 9, 10, 11, 12, 13, 91, 126, 468, and 469) and includes guidance on key topics such as what OFAC means by “blocked property” and how to verify the authenticity of an OFAC document.
OFAC will continue reviewing FAQs through an ongoing process focused on providing up-to-date and useful information to the public. OFAC will announce subsequent FAQ updates via its Recent Actions Notices.
OFAC Website Updates and FAQs Search Function
OFAC recently made changes to our website to make it more user-friendly, including updating the home page to make finding FAQs easier. Our website now has a new and improved FAQ search function that allows you to search by keyword or phrase and to filter results by specific topics or relevant sanctions programs.
FAQ Archive
In addition to updating certain FAQs and enhancing the search function, OFAC is working to make it easier for the public to see when FAQs have been updated and what has changed. Specifically, we will soon begin preserving certain older versions of amended FAQs in an FAQ archive on our website. We are continuing to assess how to make this feature as user-friendly as possible and look forward to launching it soon.
Compliance Hotline
Last year, OFAC’s Compliance Hotline received approximately 57,000 submissions — an all-time high. To keep up with the increased demand for sanctions guidance, OFAC launched a new online platform to streamline the way the public submits queries to OFAC. This platform enhances how OFAC receives and responds to hotline inquiries; specifically, it allows for improved tracking of requests and will help us analyze which questions are most frequent and where additional public guidance may be helpful.
OFAC Reporting System
To enhance processing speed and reduce reporting burden, OFAC introduced the OFAC Reporting System (ORS). ORS is a secure electronic platform for submitting reports related to blocked property and rejected transactions. It offers features such as secure messaging, bulk filing, and unique report forms. Although ORS has been available as an optional filing method since 2019, most filers now prefer using it.
Recently, OFAC amended the Reporting, Procedures, and Penalties Regulations to clarify reporting requirements and make the use of ORS mandatory for filing block and reject reports. This rule took effect on August 8, 2024.
Sanctions List Service
On May 6, 2024, OFAC formally launched the Sanctions List Service (SLS). SLS is a cloud-based platform that provides users with easy access to the most up-to-date and complete sanctions lists and sanctions list data ready for immediate download. SLS introduced a custom sanctions dataset tool to allow users to create custom datasets based upon their selection of certain sanctions lists or programs. SLS also provides easy access to an archive of OFAC’s sanctions lists in XML format (dating back to 2022). Human-readable versions of sanctions lists (dating back to 1994) remain available on OFAC’s website.
Production Submission Standards and Enforcement Information
To reflect current technological standards, on July 5, 2024, OFAC published an update to its data delivery standards, which provides general and technical guidance for submitting information to OFAC electronically. The guidance, available here, provides best practices for organizing submissions, general conventions for electronic submissions of various file types, and standards for submitting large productions. Additionally, on April 8, 2024, we updated OFAC’s table of Civil Penalties and Enforcement Information on our website to include the dates, party names, penalty or settlement amounts, and relevant documentation for enforcement actions dating back to 2003.
Licensing Portal
OFAC recently updated the online Licensing Portal to provide greater transparency about the license application process. Specifically, applicants using the Licensing Portal to check the status of their applications will now receive one of ten case statuses that specify where their application is in the processing timeline. Concurrently, OFAC updated the License Hotline by revising menus and transitioning to a callback-only system. These updates are designed to help the public access the information they need faster, reduce call wait times, and improve the overall customer experience.
Conclusion
OFAC is committed to modernizing its operations and enhancing access to information to help the public understand and implement our sanctions. We welcome feedback on these updates, including recommendations on additional FAQs or public guidance topics that would be helpful for OFAC to address, via its Compliance Hotline or, if you are a subscriber to OFAC's Recent Actions Notices, through a website satisfaction survey which we will release in the coming weeks.