The Office of Foreign Assets Control, often one of the most difficult and implacable federal agencies to deal with, has announced its intent to consider COVID-19 issues when addressing “apparent violations” of its regulations.
In a release dated April 20, 2020, it stated “If a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part of its risk-based approach to sanctions compliance, to account for such challenges by temporarily reallocating sanctions compliance resources consistent with that approach, OFAC will evaluate this as a factor in determining the appropriate administrative response to an apparent violation that occurs during this period.”
It also published a a fact sheet that summarizes existing exemptions and authorizations to provide humanitarian assistance in the context of the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related? sanctions programs.