The Office of Foreign Assets Control (“OFAC”), a branch of the United States Department of the Treasury, administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. Its primary tool is its published list of thousands of individuals, businesses, organizations, vessels and other entities with which U.S. persons or entities are prohibited from doing business.

OFAC applies to all U.S. Citizens regardless of where they are working. Permanent Residents, companies located in the U.S., overseas branches of U.S. companies and certain overseas subsidiaries of U.S. companies. Consequently, an increasing number of institutions seek assistance with their OFAC compliance programs. OFAC penalties tend to vary because different statutes can trigger an addition to the OFAC list. OFAC can fine up to $10 million per violation for corporations, and up to $5 million for individuals who violate OFAC statutes.

Imagine if your company was found to have conducted business with individuals and/or entities on OFAC’s list that had financed terrorist acts – how would you explain this to the public, to officers, or to shareholders? Daylight can assist your organization ensure that this does not happen, our array of services include:

• OFAC Compliance Policy and Procedures Design and Implementation – entails an analysis of your business aimed at identifying specific OFAC risks in addition to the development of a customized compliance program with detailed policies and procedures for you and your employees to follow.
• OFAC Gap Analysis and Vulnerability Assessments – comprises a review of your existing OFAC compliance program by reviewing and comparing it to the legal requirements of OFAC and our knowledge of leading industry practices, noting both the strengths and weaknesses of the program.
• Customized OFAC Training Programs – will customize the training with you to address issues specific to your industry or business as well as any additional information deemed important by your institution.
• OFAC Batch Filtering/Analysis – will examine your OFAC filtering software to determine if it is ideally suited to a certain business line or product.
• Due Diligence for Mergers and Acquisitions – Daylight Forensic & Advisory is poised to assist and provide a complete array of OFAC compliance services to all industries.