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Embargoes and Economic Sanctions Compliance

The United States maintains a series of embargoes and economic sanctions programs that are imposed against individuals, entities and/or countries that have violated U.S. law or that pose threats to the national security interests of the United States and its allies and strategic partners.

These programs are primarily enforced by the Treasury Department’s Office of Foreign Assets Control (OFAC) through the Foreign Assets Control Regulations; however, country and end-user restrictions are also enforced under the EAR and ITAR as well. U.S. persons are prohibited from dealing with restricted parties and sanctioned countries without prior U.S. government approval.

Miller Proctor Law supports companies in their compliance with U.S. embargoes and economic sanctions programs, and provides the following services—

  • Advisory Opinions
  • Transactional guidance
  • Embargoed/Sanctioned Country and Restricted Parties List Screening
  • Determining General License or Exemption Availability
  • Preparing applications for Trade Sanctions Reform Act (TSRA) authorization
  • Preparing applications for Specific Licenses
  • Customized in-house training for U.S. and non-U.S. business units
  • Engagement of foreign distributors and agents
  • Internal audits and compliance assessments
  • Assessment of potential liability in due diligence investigations for mergers, acquisitions and divestitures
  • Assistance with on-boarding and assimilation new business units post-closing
  • Designing or enhancing effective sanctions compliance programs
  • Documented policies and procedures
  • Representation during all phases of enforcement actions, as well as assistance with voluntary self-disclosures, responses to administrative subpoenas and penalty cases