Question: A US-owned Russian subsidiary is owed a sum of monies in Russian currency by another Russian entity. The subsidiary would like to initiate action to recoup the monies. While it appears no US persons are involved nor are US dollars or financial institutions, my training was to always get an OFAC license as invariably, […]
Question: We have a foreign subsidiary located in Denmark that provided a repair service to a company located in Turkey in 2024. In 2025, this company was put on the SDN list under Russian Harmful Foreign Sanctions Regulations. Our in-depth screening only shows this entity subject to SDN OFAC sanctions and not any EU or […]
Question: I am wondering what records other members flag as being subject to the OFAC extended (from 5 to 10 years) record retention period? If a company does not deal with sanctioned countries, what should be kept for 10 years besides screening records? Do we need to keep all export records as evidence of not […]
Question: Asking the membership to understand which department conducts screening within your organization. As we try to implement a process for screening, there is discussion about who will be responsible for the manual efforts. Is it legal, trade compliance, risk management, customer service? Any thoughts or recommendations are appreciated. Answer 1: In our case we […]
Question: Company A who is a U.S. company has a wholly owned foreign susidiary, I’ll call Company B. Company B purchases items from various foreign companies and sells them internationally, but not to the U.S. One of the foreign companies (Company C) that Company B purchases from uses a manufacturer that was recently added to […]
Question: Can a US person located in the US assist with export shipments from Russia to other countries (not the US)? Answer 1: We recently reviewed a couple of scenarios with outside counsel on this very subject. I suggest you do the same at a granular level. In our case, we would be paying a […]
QUESTION: Does OFAC publish the results of license applications? We are debating whether to apply for an OFAC license to export software to an entity on the SDN list per the Venezuela sanctions. While we know our only chance to provide the software would depend upon the approval of a license application (no general licenses […]
QUESTION: Anyone have a questionnaire or process to share on how you conduct ownership information for new distributors? In which countries other than Venezuela and Russia would you recommend we conduct this check? I’d like to create a process for new distributors, agents, customers, vendors to complete a due diligence form and would like some […]
QUESTION: Anyone have a questionnaire or process to share on how you conduct ownership information for new distributors? In which countries other than Venezuela and Russia would you recommend we conduct this check? I’d like to create a process for new distributors, agents, customers, vendors to complete a due diligence form and would like some […]
