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The New “Framework for OFAC Compliance Commitments”:  What You Need to Know

Upon purchase, an email will be sent that provides a link to view the webinar recording, a copy of the presentation, and a certificate of completion. Access to view the webinar recording will be available for one year from the purchase date.

On May 2, 2019, the United States Treasury’s Office of Foreign Assets Control (OFAC) issued a Framework for OFAC Compliance Commitments.  The Framework was expressly designed to provide “OFAC’s perspective on the essential components of a sanctions compliance program.”  The document also outlines how these elements will be considered in the event of an enforcement action, and analyzes the root causes of economic sanctions violations that OFAC has identified in its investigative process.  The document is essential reading for all compliance professionals, and its lessons must be incorporated into any effective compliance program.  This webinar will cover the Framework itself and the lessons it provides for adapting U.S. sanctions compliance policies and procedures.  The webinar will also cover how the Framework should affect U.S. sanctions investigations and interactions with OFAC officials as part of the enforcement process.

We will cover the following during the webinar:

  • The nuts and bolts of the Framework
  • The necessary elements of a post-Framework U.S. sanctions compliance program
  • Conducting U.S. sanctions investigations in light of the Framework
  • Interacting with OFAC in light of the Framework
    • Voluntary Disclosures
    • Settlements
    • Penalties

Who Should Attend:

  • Compliance professionals
  • In-House counsel
  • Outside counsel
  • Anyone else who may need to spot, manage, or conduct an internal investigation into export controls or U.S. sanctions issues.

The webinar will be presented through PowerPoint slides and will include video and commentary from Timothy P. O’Toole, a member of the law firm of Miller & Chevalier Chartered, in Washington D.C.  Ranked as one of the nation’s leading international trade lawyers by Legal 500, Tim has defended defendants facing government enforcement actions for over two decades and has focused on defending matters arising under export controls and the U.S. sanctions laws.  He has vast experience dealing with U.S. regulators and enforcement agencies, including the U.S. Department of Justice, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Commerce Department’s Bureau of Industry and Security (BIS), and the U.S. State Department’s Directorate of Defense Trade Controls (DDTC), and in providing clients with compliance advice designed to help ensure they never need to defend enforcement actions in the first place.


Computer Requirements:

Please read the Webinar Terms and Conditions before you register.

Webinar Details


July 24, 2019


1 hour 30 minutes
Comprised of 1 hour of commentary and 30 minute Q&A session



1 Participant: $150.00
2-5 Participants: $112.50 each
(25% discount for all participants)
6 or more Participants: $75.00 each
(50% discount for all participants)

ECoP® EAR or ITAR Renewal Credits


Event #: 13778

CES: 1.5