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United States: Reminder of sanctions compliance requirements (COVID-19)

Reminder of sanctions compliance requirements, COVID-19

The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department today issued a notice to encourage persons—including financial institutions and other businesses—to communicate OFAC compliance concerns related to the coronavirus (COVID-19) pandemic.

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The OFAC release notes that because of the COVID-19 global pandemic, entities may experience delays in the ability to meet the deadlines associated with regulatory requirements administered by OFAC, and such entities are encouraged to contact OFAC as soon as practical. The notice specifically cites as examples requirements related to filing blocking and reject reports within 10 business days, responses to administrative subpoenas, reports required by general or specific licenses, or any other required reports or submissions.  

The release notes that the COVID-19 pandemic can cause technical and resource challenges for organizations. 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, OFAC stated that it will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.  OFAC will address these issues on a case-by-case basis.


For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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