Sanctions: We have an OFAC violation: What to do!

Your institution just discovered a potential OFAC violation—now what?

Navigating economic sanctions is a high-risk area for financial institutions. A misstep can result in multi-million dollar penalties, reputational damage, and potential criminal liability. In this timely and practical session, compliance expert Justin Muscolino will walk participants through how to handle an Office of Foreign Assets Control (OFAC) violation effectively—from identification to resolution.

The webinar will include a breakdown of U.S. sanctions programs, the regulatory expectations when dealing with a sanctions breach, and strategies for risk mitigation. You’ll gain critical insights into how institutions are responding to the growing complexity of sanctions compliance in the global regulatory landscape.

Webinar Nov 20 2025, Thursday 12:00 PM EDT 60 Minutes Intermediate Level Code: GRC0000118

1. Sanctions Overview

  • What are sanctions and why do they matter?
  • Role of OFAC (Office of Foreign Assets Control)
  • Types of sanctions: Comprehensive vs. targeted
  • Sanctions programs (e.g., Iran, Russia, North Korea)

2. Sanctions Background

  • Legal and regulatory framework behind sanctions
  • How sanctions support U.S. foreign policy and national security
  • International coordination (e.g., UN, EU sanctions alignment)

3. Impact of Sanctions on Financial Institutions

  • Risk exposure across banking operations
  • Real-world consequences: Penalties, regulatory action, reputational damage
  • Key functions affected: AML, trade finance, wire transfers, KYC/CDD

4. What to Do If a Violation Occurs

  • Detection: How to identify a potential OFAC violation
  • Internal escalation and reporting channels
  • Immediate actions: Account freezing, transaction rejection
  • Filing a Voluntary Self-Disclosure (VSD) with OFAC
  • How to conduct a sanctions-related internal investigation
  • Remediation strategies and demonstrating a “culture of compliance”

5. Best Practices for Sanctions Compliance

  • Developing and implementing a sanctions compliance program
  • Screening tools and how to use them effectively
  • Third-party risk management and sanctions exposure
  • Training staff to detect and report red flags
  • Regular audits and program testing

6. Case Studies

  • Review of actual OFAC enforcement actions
  • What went wrong, and what could have been done differently
  • Lessons learned from recent high-profile violations

7. Takeaways

  • Actionable checklist for handling sanctions violations
  • OFAC resources and guidance documents
  • Template for Voluntary Self-Disclosure
  • Steps to strengthen your compliance program

  • AML and Compliance Officers
  • Financial Crimes Investigators
  • BSA Officers
  • Risk Management Professionals
  • Legal and Regulatory Counsel
  • Internal Auditors
  • Operations Managers in financial institutions
  • Anyone responsible for sanctions screening and compliance

In a global financial system, even a minor lapse in sanctions compliance can result in severe consequences. With the increasing complexity of global sanctions regimes, staying ahead of your compliance obligations is essential.

This webinar provides:

  • A clear roadmap for responding to OFAC violations
  • Tools to prevent recurring mistakes
  • Guidance on reporting obligations and best practices
  • Insight into enforcement trends and how regulators think

Whether you work in a bank, credit union, fintech company, or any regulated financial institution, this session is a must-attend for understanding how to respond effectively and minimize risk when sanctions issues arise.

DEV STRISCHEK
DEV STRISCHEK

A frequent speaker, instructor, advisor and writer on credit risk and commercial banking topics and issues, Dev is principal of Devon Risk Advisory Group and engages in consulting, speaking and training on a wide range of risk, credit, and lending topics. As former SVP and senior credit policy officer at SunTrust Bank, Atlanta, he was responsible for developing, implementing, and administering credit policies for SunTrust's wholesale lines of business--commercial, commercial real estate, corporate investment banking, capital markets, business banking and private wealth management. He also spent three years as managing director and credit approver in SunTrust's Florida commercial lending and corporate investment banking areas, respectively. Prior to SunTrust, Dev was chief credit officer for Barnett Bank's Palm Beach market. Besides stints at other banks in Florida, Missouri, and Ohio, Dev's experiences outside of banking include CFO of a Honolulu construction company, combat engineer officer in the U.S. Army, and college economics instructor in Hawaii, Missouri, and Florida. A graduate of Ohio State University and the ABA Stonier Graduate School of Banking, he earned his M.B.A. from the University of Hawaii. Dev serves as an instructor in the ABA’s Stonier Graduate School of Banking and the American Bankers Association's (ABA) Commercial Lending. He has also taught at the Florida RMA (Risk Management Association) Chapter Commercial Lending School, the Southwest Graduate School of Banking in Texas, and the Wisconsin School of Banking.  His school, conference, and workshop audiences have included participants drawn from the ABA, RMA, OCC, Federal Reserve, FDIC, FFIEC, SBA, the Institute of Management Accountants (IMA) and the AICPA. Dev has written about credit risk management, financial analysis and related subjects for the ABA's Commercial Insights, the Risk Management Association's RMA Journal, and other business professional journals. He is the author of Analyzing Construction Contractors and its related RMA workshop. A past national chair of RMA and former Florida Chapter president, Dev served as a member of the RMA Journal's advisory board and he has consulted on credit risk issues with banks in Morocco, Egypt, and Angola through the US State Department's Financial Service Volunteer Corps (FSVC).  He represented the banking industry on the Private Company Council (PCC) of the Financial Accounting Standards Board where the PCC reviews proposed and existing generally accepted accounting principles and recommends changes to GAAP that accommodate the needs of privately held companies.

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