495. Why did OFAC issue the Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws (the “Compliance Services Guidance”)?

OFAC has received numerous inquiries, many from foreign companies at outreach events, regarding whether U.S. persons may provide, and whether U.S. persons have been able to provide in the past, certain types of legal and compliance services to covered persons. The Compliance Services Guidance provides clarity in response to those inquiries. For purposes of the Compliance Services Guidance, “covered persons” means U.S. persons and foreign persons other than any person (i) whose property and interests in property are blocked pursuant to any part of 31 C.F.R. chapter V, including persons listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or (ii) to whom a U.S. person is prohibited from exporting services or from whom a U.S. person is prohibited from importing services pursuant to any part of 31 C.F.R. chapter V. The Compliance Services Guidance does not describe every allowable service relating to the requirements of U.S. sanctions laws.