Our attorneys assist with sanctions risk and enforcement

It’s no exaggeration to say that the reach and complexity of US sanctions law is increasing with every passing day. Even individuals and businesses with no presence in the United States can find themselves caught by US sanctions and on the receiving end of a formal investigation or enforcement action by the Office of Foreign Assets Control (OFAC), the office that administers and enforces US sanctions.

Our lawyers bring sanctions expertise derived from direct government experience with OFAC. We enable our clients to navigate the increasingly complex world of economic sanctions with clear, candid, and practical advice to meet their goals. 

At Exoro Law, we assist businesses and individuals dealing with the full range of sanctions concerns. Whether you’re seeking an analysis of your sanctions risk and compliance profile, require a license from OFAC to engage in activity affected by US sanctions, or need to disclose prior activity or negotiate a settlement agreement with OFAC, we will guide you through the process and work with you to achieve your objectives. Our team of experienced sanctions attorneys will liaise directly with OFAC on your behalf so that you can gain authorization for a planned transaction involving a foreign entity or government, or obtain the release of funds sent from a specially designated national (SDN). We are here to assist you throughout the process.  

Our services include:

1. Analysis of business activity to determine sanctions requirements and risk 
2. Analysis of business activity to determine compliance with US sanctions law
3. Review of contemplated business activity to identify applicable general licenses      and other regulatory exceptions
4. Drafting specific license applications to OFAC for authorization to engage in      activities otherwise prohibited by U.S. sanctions law, including Applications for the Release of Blocked Funds
5. Drafting requests for interpretive guidance on existing regulations to clarify our      client’s legal position with respect to their business activity
6. Analysis of past transactions to identify potential violations
7. Preparation and drafting of voluntary self-disclosures to OFAC
8. Preparation and drafting of inquiry and enforcement responses to OFAC
9. Creation and implementation of remedial action plans
10. Negotiation of resolutions for clients facing formal investigations and OFAC      enforcement actions
11.  Sanctions Litigation and Representation
12. OFAC SDN List Removal
13. OFAC Specific License Applications for the Release of Blocked Funds
14. Managing and Overseeing OFAC-Licensed Transactions
15. Review of contracts, including financing, shareholder, and supplier agreements
16. Negotiation and revision of contract terms to include U.S. Sanctions protections
17. Assessment of steps needed to exit/unwind transactions in a legally compliant manner

Considering the distinctive and potentially high-stakes aspects of engaging in a transaction under an OFAC license, we strongly advise individuals to maintain collaboration with their sanctions counsel throughout the licensed transactions.

Upon securing OFAC licenses for our clients, we collaborate with them to supervise and monitor their transactions, intervening only as needed to prevent any complications. As OFAC licenses can impose restrictions or specify transaction terms, it is crucial for parties to carefully consider their licenses during negotiations, contract creation, and subsequent business and commercial activities after execution.

If you would like an analysis of your sanctions risk and compliance profile, require a license from OFAC to engage in activity prohibited by US sanctions, or need to disclose prior activity with OFAC, we are here to help. We can evaluate your situation, guide you through the process, and collaborate with you to achieve your objectives with OFAC.