Trade security/ Unique risk for logistics companies and other professionals who assist companies in moving goods across borders

As sanctions enforcement continues to mature, the permutations of risks become more complex. One area where companies have significant exposure is when they can be accused of “facilitation.” It is a unique risk for logistics companies and other professionals who assist companies in moving goods across borders.

An individual cannot facilitate a transaction with a person or entity sanctioned by the US government. A violation carries a potential criminal penalty of ten years imprisonment and a significant fine.

OFAC is responsible for managing sanctions and embargoes against individual, entities and countries. OFAC maintains the list of Specially Designated Nationals (SDN) list. Broader sanctions prohibit transactions between a US person and any person or entity in Iran, North Korea, Sudan and Syria.

Sanctions Enforcement – Facilitation Violations