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TECHNOLOGY, AI & COMPETITION

OFAC compliance

OFAC compliance in the Technology, AI and Competition sector is under active pressure, with the U.S. Department of the Treasury's Office of Foreign Assets Control tightening scrutiny on cloud infrastructure providers, semiconductor exporters, and AI model licensors that touch sanctioned jurisdictions. The U.S. Department of Commerce Bureau of Industry and Security has layered export control rules on top of OFAC's SDN-list obligations, meaning technology firms now face dual-agency exposure on a single transaction. Compliance teams are auditing API access logs and third-party reseller agreements against OFAC's 50 Percent Rule before renewing enterprise contracts.

Watch

  • OFAC 50 Percent Rule applied to AI model sublicensing and API distribution chains
  • BIS Entity List additions targeting semiconductor and advanced computing suppliers
  • Cloud service provider blocking obligations under OFAC's Russia-related General Licenses
  • Treasury OFAC civil penalty pattern: self-disclosure credit in technology sector settlements

Recent material activity in Technology, AI & Competition

Active monitoring in place across Technology, AI & Competition. Material developments related to ofac compliance will appear here as they are published.