THE CHALLENGE
OFAC enforcement may arise from screening, financial-institution reports, third-party information, public allegations, or agency review. Initial contact may be informal outreach, an information request, or a subpoena. Penalties, reputational harm, and disruption can follow, while incomplete responses or disclosures can affect exposure, mitigation credit, and OFAC’s assessment of cooperation.
How does this get solved?
We begin by assessing what OFAC knows, what it seeks, and the potential exposure. We preserve records, investigate the conduct, align stakeholders, and evaluate self-disclosure. Using verified facts, applicable law, existing controls, and remediation, we build a consistent response and manage the process toward resolution.
Rapid intake of listing matters
When OFAC makes contact, we preserve key records, coordinate external communications, assess exposure, and identify what triggered the inquiry and what OFAC is seeking.
Initial intake typically includes: OFAC correspondence or subpoenas; the underlying conduct; parties and ownership; transaction records; screening results; internal and third-party communications; prior submissions; relevant policies, remediation, and a timeline of events.
our approach
How we build a delisting record
Stabilize and assess
Identify what OFAC is seeking, the conduct under review, and whether the issue is an apparent violation, control gap, or misunderstanding. Preserve records, coordinate communications, map the relevant parties and transactions, and evaluate whether disclosure or a broader investigation is appropriate.
Build the record
Create a verified account of what occurred, what controls applied, and what remediation followed. Address ownership, routing, screening, and control issues directly. Organize supporting materials so external submissions remain consistent with internal findings.
Manage the process
Respond completely and consistently while managing document productions, interviews, and follow-up questions. Coordinate remediation, reporting, communications, and continuity planning. As OFAC’s position develops, evaluate administrative responses, settlement strategy, and litigation preparedness.
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 DETAILSFacing an OFAC investigation or enforcement inquiry?
We help companies, financial institutions, and international organizations assess exposure, respond to regulators, and manage sanctions-related investigations before they escalate further.