Since the beginning of August, there have been three publicly released enforcement actions by the Office of Foreign Assets Control (OFAC), including two within the same week. These enforcement actions are showing that OFAC is taking a close look at two different things: 1) the constant updating and updated screening of names on one’s list when providing services to someone, and 2) taking the proper steps when engaging an activity that would be eligible for a license.
Regularly screening your sanctions list.
On August 2, 2016, OFAC issued a finding a violation to Humana Incorporated, which is the parent company of Kanawha Insurance Company, for violations of the Foreign Narcotics Kingpin Sanctions Regulation. The Foreign Narcotics Kingpin Sanctions Regulations can be found in 31 CFR Part 598.