United States Sanctions
The United States Department of the Treasury is a branch of the U.S. Government that, among other things, is responsible for administering and enforcing U.S. sanctions. Within the Treasury Department, the Office of Terrorism and Financial Intelligence (TFI) 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.
​
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.
​
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)
​
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 consider OFAC sanctions to be among the most impactful sanctions globally, for various reasons, including the ubiquitous use of the U.S. dollar (USD) in international trade. OFAC currently administers more than 30 sanctions programs targeting specific types of conduct, foreign governments and jurisdictions, non-state actors in the international arena, and specific sectors of foreign economies.​
​
Unlike its European counterparts, OFAC is highly active in the enforcement of its sanctions. Indeed, the concept of “compliance through enforcement” is often invoked in discussions of OFAC policy. The landmark BNP Paribas case demonstrated how serious the U.S. Government is with respect to sanctions violations.
​
This chart shows the 10 largest enforcement actions of OFAC. The large numbers are one of the reasons OFAC's sanctions are taken very seriously by U.S. and non-U.S. persons alike.
