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Insights · Export controls and sanctions

OFAC to consider COVID-19 issues when addressing “apparent violations” of its regulations

The Office of Foreign Assets Control, often one of the most difficult and implacable federal agencies to deal with, has announced its intent to consider COVID-19 issues when addressing “apparent violations” of its regulations.

In a release dated April 20, 2020, it stated “If a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part of its risk-based approach to sanctions compliance, to account for such challenges by temporarily reallocating sanctions compliance resources consistent with that approach, OFAC will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.”

It also published a a fact sheet that summarizes existing exemptions and authorizations to provide humanitarian assistance in the context of the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related? sanctions programs.

This article is general information, not legal advice, and reading it does not create an attorney-client relationship. The law described here changes, sometimes weekly. For advice about your own entries, notices or deadlines, contact the firm.

Neil B. Mooney, founder of the firm

Neil B. Mooney

Founder, of counsel · English · Español

Twenty-seven years on the cargo ramp, in the brokerage house and running his own forwarding and NVOCC group before law school. Licensed Customs broker since 1978, lawyer since 1999, and he consults on virtually every case.

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