U.S. economic sanctions, or embargo regulations, broadly prohibit most transactions between a U.S. person and persons or entities in an embargoed country, such as Cuba, Iran, North Korea, Syria, and Sudan. This prohibition includes importation and exportation of goods and services, whether direct or indirect, as well as "facilitation" by a U.S. person of transactions between foreign parties and an embargoed country. More limited embargoes may block particular transactions or require licenses under certain circumstances for exports to a number of countries, including Burma, Liberia, and Zimbabwe. In addition to the country programs, there also are sanction programs aimed at a wide array of individuals from international terrorists to narco-trafficers and weapons of mass destruction proliferators.
While most embargo regulations are administered by the Treasury Department Office of Foreign Assets Control ("OFAC"), the Commerce Department Bureau of Industry and Security ("BIS") has jurisdiction over certain exports prohibitions, as is the case with exports to Syria. Economic sanctions programs are country- and program-specific and very detailed in the specific prohibitions. Companies must be careful not to assume that a certain transaction that was allowable with one embargoed country is allowable in the next embargoed country.
Compliance with Sanction Laws can be complex, and the consequences of non-compliance -- including monetary fines and reputational harm -- can be severe.
This program will provide a practical overview of the Sanction Laws for companies of all sizes. It will review the central tenets of the Sanctions Laws and how to assess whether a license is required for a particular transaction, explain key principles, and offer thoughts on questions and considerations that companies should take into account in seeking to comply with the Sanctions Laws.