OFAC PUBLISHES INTRODUCTORY GUIDE TO BOOST COMPLIANCE
July 15, 2026
Eckert Seamans has prepared the information in this update for educational purposes only. It does not constitute legal advice nor substitute for legal advice. Neither your receipt of information from this website nor your use of this website to contact Eckert Seamans or one of its attorneys creates an attorney-client relationship, as the firm may, for example, already represent another party involved in your matter. Accordingly, you should not provide confidential information to Eckert Seamans. Persons seeking legal advice should consult a licensed professional attorney in their state. The firm’s Terms of Use, Legal Notice, and Disclaimer detailed herein are expressly incorporated into the Aviation Regulatory Update.
On June 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control published an informational guide to provide U.S. and foreign entities with a better understanding of how OFAC-administered sanctions are enforced and how failure to comply with those sanctions could result in substantial civil and criminal penalties. The informational guide addressed several OFAC “hot” topics, including but not limited to, the following:
- Persons and entities who must comply with OFAC regulations;
- Internal control and risk management best practices;
- Annual and on demand reporting requirements due to OFAC sanctions;
- Recordkeeping requirements for each transaction subject to OFAC’s regulations, including transactions processed pursuant to license(s);
- Consequences of noncompliance and related enforcement actions carried out pursuant to OFAC’s Economic Sanctions Enforcement Guidelines; and
- Voluntary self-disclosures of apparent violations via OFAC’s Disclosure portal (available here).
Since OFAC sanctions can apply broadly to prevent dealings with an entire country (e.g., North Korea) or a particular foreign governmental regime, commercial entities operating across the globe, including foreign airlines, should routinely review the Specially Designated Nationals and Blocked Persons List (available here) and other OFAC sanctions lists to verify that they are not interacting with any individuals or entities that could be sanctioned due to some nexus to a targeted country, geographic region, activity, or regime. This frequently requires U.S. and foreign entities operating internationally to adopt a risk-based approach to compliance so they can routinely update their sanctions compliance program based on individualized country-by-country risk profiles.
This Aviation Blog Post is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
Share This Post
Authors
