Recognizing the operational challenges facing many institutions during the pandemic, the Office of Foreign Assets Control encouraged banks to contact the office as soon as possible if they are experiencing difficulties meeting any of the deadlines for filing required reports.
Affirming its risk-based approach to sanctions compliance, OFAC added that “if a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part of its risk-based approach . . . to account for such challenges by temporarily reallocating sanctions compliance resources consistent with that approach, OFAC will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.”
OFAC also issued a fact sheet reminding banks of existing exemptions and authorization to provides humanitarian assistance to several countries during the pandemic, including Iran, Venezuela, North Korea, Syria, Cuba, Russia and Ukraine.