Alston & Bird has one of the most active and experienced Office of Foreign Assets Control (OFAC) sanctions and embargoes practices in the United States. For over 30 years, we have represented a wide variety of U.S. and foreign companies with international operations, including some of the largest financial institutions in the world, as well as major industrial companies in the pharmaceutical, telecommunications, energy, manufacturing and defense sectors.
Compliance with sanctions programs can present a significant challenge for global companies. The U.S. government is increasingly willing to impose restrictions on trade and financial transactions with targeted governments and entities, and it is difficult for companies to navigate the multitude of regulatory schemes implementing sanctions programs and embargoes. The extraterritorial reach of certain OFAC regulations can create particular challenges for foreign subsidiaries or branches of U.S. entities.
An increasingly important part of our OFAC work has been enforcement; we have vigorously defended against and successfully negotiated numerous enforcement matters, including complex criminal proceedings brought jointly by OFAC, the Department of Justice and other agencies involving internal reviews and “look backs.” In addition, we frequently counsel on specific transactions; seek regulatory interpretations; monitor and advise on regulatory, legislative and enforcement developments; assist in the development of compliance programs; and prepare voluntary disclosures of violations to OFAC. Our lawyers also have obtained innumerable specific licenses from OFAC for clients to authorize otherwise prohibited transactions with Cuba, North Korea, Iran, Sudan, Burma and other sanctioned countries.