With the turmoil in the world and the ongoing activities of bad actors, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has been busy in 2023. Along with nearly constant updates to sanction lists, OFAC has penalized nine companies and one individual for violations to date in 2023.
It has issued ten penalties, settlements or findings of violation, totaling $557 million. The bulk went to one company: a $508 million penalty to British American Tobacco PLC. Others OFAC settled with include Microsoft Corporation ($2.9 million), Wells Fargo Bank ($30 million) and most recently, Construction Specialties Inc. ($660,954).
Recent OFAC actions include adding a host of individuals and entities to the Specially Designated Nationals (SDN) List. There have been a few removals as well. OFAC’s website includes 12 pages of recent actions taken since the start of the year.
It is essential to keep up. As detailed here, keeping your vendor file free of sanctioned entities involves checks in a few directions. First is to have checked all your vendors against OFAC’s list. Once you have done that, you must then check new vendors against the sanction lists, and you must also check new sanction list additions against your existing vendor list.
For example, as we previously reported, Microsoft got into trouble because OFAC added a vendor to its list that was already in Microsoft’s vendor database. The company was not on the list when Microsoft started doing business with it. But when OFAC added it, the software giant didn’t stop doing business with it. The change in status slipped past Microsoft, a $3 million “whoops.” Of course, that fine would have been much more significant, but Microsoft self-disclosed the slip in the “non-egregious” case and took other remedial actions in addition to terminating the vendor relationship.
What To Do
The best way to protect against inadvertently violating sanctions is to automate your sanctions screening. Even a small company will find it challenging to keep up, particularly in keeping track of their current vendor list as opposed to one-off checking of new vendors. See How to Automate Sanction Screening.
OFAC New Video Series
For those new to managing vendor onboarding and vendor information, OFAC has just released a new informational series of videos to help communicate its message and provide training for U.S. organizations to comply. It might not compete with your favorite streaming show, but is worthwhile particularly for new vendor information team members. Find the first two videos in the series here. And keep up to date. Don’t transact with the bad actors out there.
For information on how VendorInfo can automate sanctions screening for you, contact us.