United States Sanctions
The United States Department of the Treasury is a branch of the U.S. Government that among other things deals with United States sanctions. Within the Treasury Department, we have the Office of Terrorism and Financial Intelligence (TFI) which is tasked with intelligence and enforcement functions aimed at safeguarding the financial system against illicit use and combating rogue nations, terrorist facilitators, weapons of mass destruction (WMD) proliferators, money launderers, drug kingpins, and other national security threats.
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Two components of TFI are led by Assistant Secretaries. The Office of Terrorist Financing and Financial Crimes (TFFC), is the policy and outreach apparatus for TFI. The Office of Intelligence and Analysis (OIA) is responsible for TFI's intelligence functions, integrating the Treasury Department into the larger intelligence community (IC), and providing support to both Treasury leadership and the IC.
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TFI also oversees several component offices and bureaus like the Office of Foreign Assets Control (OFAC), the Treasury Executive Office for Asset Forfeiture (TEOAF), and the Financial Crimes Enforcement Network (FinCEN).
The Office of Foreign Assets Control (OFAC)
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The best way to introduce OFAC is to look at its mission statement. OFAC's mission, as stated on the Treasury website is:
"The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under US jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments."
Many believe OFAC sanctions are the most impactful sanctions globally for various reasons including the ubiquitous use of USD in international trade. OFAC currently administers more than 30 sanction programs targeted at specific conducts, foreign governments, foreign jurisdictions, non-state players in the international arena, specific sectors of the foreign economy, etc.
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Unlike its European counterparts, OFAC is very active in the enforcement of its sanctions. In fact, many speak about "compliance through enforcement" when it comes to the OFAC policy. The hallmark case of BNP Paribas proved how serious U.S. Government is when it comes to sanction violations. This infographic prepared by Refinitive shows the number and the size of fines banks have paid since 2010 related to sanctions violations. For more information about the OFAC enforcement actions please click here.
