USAID has issued a Federal Register Notice requesting input on their proposal to expand reporting requirements on OFAC sanction violations to strengthen their monitoring of compliance and its impact on humanitarian and development assistance, including:
- Reporting on incidents involving sanctioned individuals and entities, such as amount, date, location, and identity of individual or entity receiving payment in the form of taxes, tolls, or fees. The report may also include a description of how the payment facilitated the assistance activity and any remedial steps taken to address the issue.
- Re-emphasizing record keeping of transactions subject to OFAC sanctions.
- Emphasize reasonable due diligence to minimize impermissible benefit to any sanctioned individual or entity.
- Provide data to USAID to assess impact.
Presumably reporting an OFAC violation incident will help mitigate repercussions while failure to report may entail heavier consequences. The time to weigh in is now.
Review the Federal Register Notice here.
