THE CHALLENGE
Sanctions programs often rely on automated screening without addressing ownership, transaction routing, intermediaries, or geographic risk. Unclear responsibilities and escalation procedures can produce inconsistent decisions and weak documentation, making those decisions difficult to defend under scrutiny.
How does this get solved?
We assess the organization’s sanctions exposure and how its controls work in practice. We review governance, risk assessment, screening, escalation, documentation, testing, training, and recordkeeping, then build a risk-based program with clear roles, practical playbooks, and ongoing updates.
Rapid intake of listing matters
When building or revising a sanctions compliance program, the priority is understanding the organization’s business, existing controls, and areas of regulatory exposure. We move quickly to identify what procedures exist, where operational gaps create risk, and what OFAC would likely examine.
Initial intake typically includes: existing sanctions policies and risk assessments, products and services, customers and counterparties, geographic exposure, screening tools and vendors, name-matching thresholds, ownership and control procedures, escalation workflows, management oversight, training materials, testing and audit results, prior OFAC inquiries or findings, transaction volume, and organizational structure.
our approach
How we build defensible compliance programs
Assess risks and gaps
What changes outcomes is how the record is built from day one. Evidence and arguments are developed for real scrutiny, including judicial review, even when the goal is to resolve the matter within OFAC’s administrative process. Former OFAC perspective shapes what to prove, where the weak points will be, and when escalation is necessary. And because delisting often collides with real-world business constraints, the strategy is built to coordinate licensing, unblocking, and counterparty continuity so operations do not stall while the petition moves.
Controls and playbooks
Identify what OFAC relied on and what the designation actually alleges. Pinpoint the gaps to close, the assumptions to rebut, and the criteria the petition must meet. Map the fact pattern, ownership and control, counterparties, and transaction flow so the theory is coherent and verifiable. Set the strategy early so declarations, supporting documents, and any public-facing messaging stay aligned.
Implement, test, train
File through the right channel and manage the process through follow-ups, supplemental submissions, and agency questions. Control pacing, keep the record consistent, and avoid resets caused by incomplete or conflicting submissions. Coordinate parallel needs that affect continuity, including licensing, unblocking, and counterparty communications, while the delisting petition advances. Prepare escalation if the process stalls, including litigation strategy when the facts and posture support it.
Latest outcomes
Outcomes that keep you operational
Humanitarian operations preserved amid terror-financing designation threat
A large international humanitarian relief charity facing threatened OFAC designation on terror-financing allegations prevented listing through pre-designation advocacy, credible counter-terrorist-financing procedures, and resolution of frozen charitable transfers.
SEE THE DETAILS
Platform operations secured amid sanctioned-party access allegations
A global cryptocurrency exchange facing threatened OFAC designation for sanctioned-party access prevented listing through coordinated pre-designation defense, independent investigation, and transparent agency engagement.
SEE THE DETAILSNeed a sanctions compliance framework that works operationally?
We help organizations build policies, procedures, controls, and compliance playbooks designed for real-world OFAC risk across global operations.