SIA Submits Comments to the OFAC on Economic Sanctions Enforcement Guidelines

The Securities Industry Association (SIA)* provides comments to the Office of Foreign Assets Control (OFAC) on economic sanctions enforcement guidelines. SIA suggests that to further government industry cooperation, OFAC should make several changes to the proposed enforcement guidelines: expand the circumstances in which it issues “warning letters”rather than pursuing civil penalties; modify its list of mitigating and aggravating factors; make civil penalty decisions within 180 days of receiving a response from an alleged violator; provide safe harbor procedures; and align all proposed penalties of mitigating circumstances of which OFAC is aware. SIA hopes these comments will encourage industry cooperation and furthers U.S. foreign policy and national security objectives.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.