Office of Foreign Assets Control Reviews Activities of Nonprofit Organizations in Sanctioned Countries

Nonprofit organizations that engage in international activities need to understand the role of the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) in administering and enforcing U.S. embargoes that prohibit certain activities and transactions in specified countries. OFAC administers and enforces economic and trade sanctions against targeted foreign countries, terrorists, international drug traffickers, and weapons dealers. OFAC is probably best known for enforcing the economic and trade sanctions against Cuba, but there are a number of other countries and foreign nationals subject to similar embargoes, many in underdeveloped parts of the world where nonprofits do substantial work. Penalties for even technical violations can be high and may be made public, potentially resulting in significant reputational harm and posing challenges for future fundraising efforts. Accordingly, nonprofits with operations in sanctioned countries should be aware of these embargoes and may need to implement training programs and specific procedures to comply with U.S. sanctions.

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