Office of Foreign Assets Control (OFAC)

Step Type: Text

What learners will learn: A general overview of the OFAC.

Step Description:
This step introduces the Office of Foreign Assets Control (OFAC) and its authority to enforce U.S. economic sanctions in support of national security and foreign policy objectives.

Summary of Content:
Learners will understand OFAC’s role within the U.S. Department of the Treasury and its power to block assets and restrict transactions involving sanctioned individuals, entities, or countries. Acting under Presidential and legislative authority, OFAC enforces sanctions based on U.S. interests and international mandates. These measures aim to influence foreign behavior and prevent threats without military action.

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Step Type: MultiChoice

What learners will learn: General facts about the OFAC.

Step Description:
This active recall step challenges learners to apply their understanding of OFAC's mission, structure, authority, and the scope of its compliance obligations.

Summary of Content:
Through multiple-choice questions, learners reinforce knowledge of OFAC's responsibilities, the sanctions it enforces, and the entities required to comply.

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Step Type: Text

What learners will learn: What SDNs are and the responsibilities and obligations of the OFAC.

Step Description:
This step covers the Specially Designated Nationals (SDN) List maintained by OFAC, outlining its purpose, what’s included, and the responsibilities of financial institutions in screening and responding to potential matches.

Summary of Content:
Learners will understand that the SDN List identifies individuals, entities, and countries sanctioned by the U.S. government. These parties are barred from conducting business with U.S. persons or institutions. The list includes terrorists, narcotics traffickers, sanctioned state actors, and, as of July 1, 2025, some officials from the International Criminal Court. Financial institutions are required to maintain up-to-date screening systems, follow a documented OFAC compliance program, and take a risk-based approach to compliance. If a potential SDN match is found, staff must verify the match carefully and follow internal escalation procedures. False positives are common, so diligence and adherence to bank policy are essential.

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Step Type: True or False

What learners will learn: Restrictions around SDNs.

Step Description:
This step uses True or False questions to reinforce learner understanding of the Specially Designated Nationals (SDN) list, who appears on it, and the obligations that U.S. persons and institutions must meet when it comes to OFAC compliance.

Summary of Content:
Learners will evaluate statements about who is listed on the SDN, what those listings mean for transactions, and recent updates affecting who must be screened.

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Step Type: Streak

What learners will learn: The responsibilities and obligations of the OFAC.

Step Description:
This step challenges learners to test their understanding of what OFAC expects from financial institutions, including how to manage risk, handle potential matches, and avoid violations.

Summary of Content:
By reviewing compliance requirements, escalation protocols, and examiner expectations, learners will better understand the practical steps financial institutions must take to stay compliant.

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Step Type: Text

What learners will learn: The scope of OFAC's authority.

Step Description:
This step explains OFAC’s enforcement authority, the consequences of non-compliance, and how penalties are assessed. A real-world example illustrates the risks and the importance of a strong OFAC compliance program.

Summary of Content:
Learners will understand that OFAC has the authority to impose both civil and criminal penalties for violations of U.S. sanctions. Penalties are based on factors such as the severity of the violation, involvement of senior leadership, and the strength of the institution’s compliance program. A key case study—Standard Chartered Bank’s $639 million settlement—demonstrates how failures to block transactions tied to sanctioned countries or individuals can lead to massive financial and reputational consequences. The case reinforces the importance of maintaining effective screening processes, internal controls, and risk-based OFAC compliance programs that adapt to evolving sanctions, including recent 2025 additions targeting ICC-related individuals.

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Step Type: True or False

What learners will learn: The authority granted to the OFAC.

Step Description:
This step helps learners distinguish between true and false statements related to OFAC’s enforcement powers, including civil penalties, compliance program evaluation, and bank responsibilities.

Summary of Content:
Using scenario-based questions, learners review key facts about OFAC’s enforcement toolkit and the consequences of poor compliance—financial and otherwise.

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Step Type: Streak

What learners will learn: The lessons from OFAC's settlement with SCB.

Step Description:
This step explores the 2019 OFAC enforcement action against Standard Chartered Bank, revealing real-world compliance risks and the importance of adhering to sanctions regulations.

Summary of Content:
Learners walk through the timeline, penalty amounts, and violations that led to the global $1.1 billion settlement involving multiple U.S. and U.K. authorities.

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Step Type: Crossword

What learners will learn: An overview of the OFAC course.

Step Description:
This crossword-style challenge helps learners consolidate key concepts from the OFAC course in an engaging format that reinforces terminology and definitions.

Summary of Content:
Clues and keywords span OFAC functions, legal terms, compliance roles, and historical insights. It’s a comprehensive review of everything covered in the module.

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