Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance on the provision of certain services relating to the requirements of U.S. sanctions laws (the “Compliance Services Guidance”). The Compliance Services Guidance does not reflect a change in OFAC’s policy with respect to the provision of these types of legal and compliance services. The Compliance Services Guidance responds to numerous inquiries received by OFAC, many from foreign companies at outreach events, relating to whether U.S. persons, including U.S. attorneys and compliance personnel, may provide certain services described in that guidance.
OFAC is also publishing a number of new Frequently Asked Questions pertaining to the Compliance Services Guidance.