Yes, I am going to hop on my soapbox and whine about yesterday’s Iran-related release that I decomposed into three posts…

But, first, I’m going to head some of you off at the pass as you ask: yeah, but doesn’t OFSI sometimes update multiple things at once? Yes, but… they provide a separate Sanctions Notice for every set of updates so, if I wanted to, I could post all 3 of them distinctly… easily.

As you can tell, I’m not fond when an OFAC release contains multiple types of updates at once. Some of it I understand: a lot of the Iran designations also get the double-whammy of a counter-terror designation, and it makes sense to issue related General Licenses (e.g. wind-down GLs) with designations.

But, I really wish that when there are designations from distinct OFAC programs, they’re issued separately – or, at least, broken up within the Recent Actions item (e.g. like those tables OFSI includes at the top of its emails). It makes it clearer what’s being done to whom; after all, you’re not loading that text into your screening system, are you?

That, however, is not the worst offender – yesterday’s Iran-related release was. Not only were there designations and licensing updates, but they felt it necessary to include an enforcement action against an individual. For an individual, it was a pretty hefty settlement, but what was the reasoning for making the update even more bloated? It’s not like you’re going to issue a press release about it. How many of you out there are going to read that enforcement release in the service of informing your compliance program?

IMHO, OFAC releases should be geared to make us in the sanctions world more effective and stuffing a lot into a single release that we then need to decompose does not accomplish that.

As the Human Torch would say, flame off… till next time