A Review of GWA’s OFAC Compliance Policy

What's NewOne of the most common questions we get from potential clients and vendors is why we do business in some countries and not in others.  We have done business in over 50 countries since we started our operations in 2005.  Because we are a U.S.-based company, there are many laws and advisories that we follow to protect the interests and safety of our staff, vendors and clients.

Sometimes because of circumstances beyond our control, we have to postpone or cancel in-person programming or consultations based on travel warnings issued by the US Department of State.

Due to the policies of global shipping and courier companies, which include restrictions by the United States Postal Service (USPS), delivery of print curriculum, publications and other materials for certain countries may not be available. Please check with your local carrier to determine the availability of delivery before ordering the print version of our curriculum, publications and other materials.

We also updated our OFAC compliance policy recently, and thought this would be good time to present it here for transparency sake.

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments.

Global Wire Associates has a higher OFAC risk profile because it conducts business in all regions of the world. Because sanctions programs differ based on specific U.S. foreign policy and national security benchmarks, specific prohibitions may vary depending on the country.  Global Wire Associates cannot do business with persons residing in countries currently listed on the OFAC comprehensive and significant sanctions program list – Cuba, Iran, Syria, North Korea, Sudan, and the Crimea region of Ukraine.  The full sanctions list with explanations can be viewed here.

Global Wire Associates also cannot do business with Specially Designated Nationals (“SDNs”) regardless of their location. If you attempt to register for an online or in-person program or globalwireonline.org account despite US sanctions that prohibit Global Wire Associates from doing business with you, we are legally required to cancel your registration and we cannot refund your payment.  Global Wire Associates, its digital imprint Global Wire Books and it’s design studio Global Wire Design, only works with affiliated organizations that comply with OFAC sanctions.

All employees and contractors of Global Wire Associates are to execute due diligence before performing and finalizing any sales agreements and financial transactions with clients. We have developed a process for regularly checking clients against the Specially Designated National List (SDN) and Blocked Persons list. This can be done by using the official Sanctions List Search online portal. You can also view or download a PDF or text version of the list. 

Additionally, we may request that clients and potential new employees and contractors of Global Wire Associates to provide us with documentation to help prove their identity for business verification purposes.  Global Wire Associates will report any suspicious transactions to OFAC and other appropriate financial intelligence organizations.

OFAC violations have serious consequences. Persons not complying with OFAC sanctions are liable for significant penalties, even if their action was inadvertent or uninformed. Penalties include:

  • Civil penalties: $US250,000 or twice the amount of each underlying transaction up to $US1,075,000 per violation
  • Criminal penalties: $US50,000 to $US10,000,000 fine; 10-30 years in prison
  • Publication of penalty: OFAC publishes the names of companies that have been penalized

If you have any questions, please contact info(at)globalwireonline(dot)org.

Posted in Global Wire Associates.

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