At Large: OFAC creates titanic problem for compliance chiefs

Last week, OFAC — the Treasury Department’s Office of Foreign Assets Control — published a 35-page “advisory,” along with the State Department and U.S. Coast Guard. The advisory “reflects the U.S. government’s commitment to work with the private sector to prevent sanctions evasion . . . with a focus on Iran, North Korea, and Syria.”

The problem is this: Ninety percent of the global supply chain moves on the seas, OFAC said. In the maritime transport industry, certain “malign actors” (aka smugglers) know all the old ways to cheat, and have learned some new ways too. OFAC described some (but not all) of the tricks bad actors use to evade the Iran, North Korea, and Syria sanctions.

One is left to wonder how a compliance department with normal resources is supposed to deal with all this.

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