Economic sanctions have become a key tool for the United States (and other nations) to address national security threats, foreign policy concerns and geopolitical developments deemed adverse to U.S. interests, such as terrorism, narcotics trafficking, nuclear proliferation, anti-democratic policies, human rights violations, and “malicious cyber-enabled activities.” The U.S. is the most prolific user of economic and financial sanctions, including freezing assets, imposing import and export bans, blocking sanctioned entities from the U.S. banking system and subjecting violators of U.S. sanctions programs to substantial monetary penalties.
The number of sanctions programs and their complexity continues to evolve and expand. U.S. sanctions programs are primarily administered by the Treasury Department’s Office of Foreign Assets Control (OFAC), although the Departments of State and Commerce and other agencies also have significant roles. Any company or entity operating around the world, be it in the form of goods, services or technology, must be cognizant of the risks of economic sanctions and the importance of meaningful due diligence.
Jacobs Global Trade provides counseling to companies and non-profits on U.S. sanctions programs and compliance obligations, including due diligence requirements, such as in connection with proposed transactions or acquisitions or mergers. We prepare license applications as well as voluntary disclosures where appropriate, to assist clients in mitigating penalties.
Jacobs Global Trade also assists with the development of compliance policies and systems, as well as training.