OFAC compliance
Trade and geopolitical risk compliance sits at the center of the most active U.S. sanctions enforcement cycle in a decade, with the U.S. Department of the Treasury's Office of Foreign Assets Control expanding its Specially Designated Nationals list at a pace that outstrips most internal review cadences. The U.S. Department of Commerce Bureau of Industry and Security and the U.S. Department of State Directorate of Defense Trade Controls have layered export controls and foreign direct product rules on top of OFAC designations, meaning a single counterparty can trigger exposure across three parallel frameworks. Compliance teams are cross-referencing beneficial ownership data against updated SDN entries before each transaction cycle, not on a quarterly schedule.
Watch
- SDN list amendments targeting Russian and Chinese dual-use technology entities
- OFAC 50 Percent Rule: indirect ownership exposure through newly designated parents
- BIS Entity List additions that overlap with existing OFAC-sanctioned counterparties
- General License expiration dates for wind-down authorizations in active conflict regions
- OFAC enforcement actions citing inadequate third-party due diligence as the primary violation
Recent material activity in Trade & Geopolitical Risk
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OFAC designates 14 entities linked to Russian defense procurement network
The Treasury Department's Office of Foreign Assets Control added 14 entities and 6 individuals to the Specially Designated Nationals list for their roles in procuring critical technology components for Russia's defense i…
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BIS adds 22 Chinese semiconductor entities to Entity List for advanced chip diversion
The Bureau of Industry and Security expanded export controls targeting Chinese semiconductor entities found to be diverting advanced computing chips through third-country intermediaries. New license requirements affect i…
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