Speakers will use a hypothetical case study to examine:

• What to do after identifying a potential violation (internal and external damage control; record keeping; stop-gap remedial measures and corrective actions)
• Factors to consider when deciding whether to make a voluntary disclosure (legal and business risks; applicable jurisdictions; threshold triggers under the relevant sanctions programs; knowing which entity will report; knowing which entity will assume potential liability)
• Best practices for engaging with OFAC (anticipating OFAC’s concerns; format, structure, timing and level of expected detail in Initial Notification and Final Reports)
• Using OFAC’s Settlement Guidelines to structure the disclosure
• Communicating with internal and external stakeholders / SEC Reporting