OFAC to consider COVID-19 issues when addressing “apparent violations” of its regulations

The Office of Foreign Assets Control, often one of the most difficult and implacable federal agencies to deal with, has announced its intent to consider COVID-19 issues when addressing “apparent violations” of its regulations.  

In a release dated April 20, 2020, it stated “If a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part of its risk-based approach to sanctions compliance, to account for such challenges by temporarily reallocating sanctions compliance resources consistent with that approach, OFAC will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.”

It also published a a fact sheet that summarizes existing exemptions and authorizations to provide humanitarian assistance in the context of the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related? sanctions programs.