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OFAC Enforcement
A purchase order arrives for a component a company has sold for years. The customer identifies a new defense program, and engineering reports that the requested version differs only in its mounting arrangement. Before committing to delivery, the supplier must determine whether its existing export classification still applies, whether the records support that conclusion, and what authorization the transaction requires.
An established supplier asks a U.S. buyer to send payment to an unfamiliar company in another country. The goods and price remain unchanged, but the recipient does not appear in the original contract. The supplier describes the arrangement as a convenient settlement mechanism. Sanctions screening produces no match.
Artificial intelligence is rapidly becoming part of ordinary business infrastructure. Companies now use AI to provide professional services, operate cloud platforms, automate procurement, generate software, administer payments, manage logistics, analyze investments, support customers, design products, and make increasingly autonomous commercial decisions.
An anti-money laundering program may appear comprehensive on paper while failing in practice. An institution may collect identification documents without understanding its customers, install monitoring software without confirming that relevant transactions reach the system, or generate alerts without ensuring timely review. The central question is whether its controls function, not merely whether policies exist.
- AML Whistleblowers: BSA and SAR Violations, FinCEN Awards, Retaliation Protections, and Financial Crime Enforcement
- Does an OFAC Sanctions Alert Trigger a Suspicious Activity Report (SAR)?
- OFAC Specific License Taking Too Long? How to Request Expedited or Priority Review
- OFAC Annual Report of Blocked Property (ARBP): What U.S. Persons Must File by September 30, 2026

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