OFAC Compliance

The increased use of economic sanctions over the past years made it necessary for any individuals and organizations including NGOs in the United States of America to ensure they are not in breach of a complex set of restrictions and various sanctions programs when engaging in an activity. Sanctions in the United States are administered by the Office of Foreign Assets Control (OFAC) in the United States Treasury. Even though OFAC has never obliged those subjected to the U.S. sanctions to have a compliance program in place, it has encouraged them to have one. Therefore, our Foundation, as a U.S. person, has started to work with an outside counsel specialized in this field to define a compliance program. The Humanitarian Peace Foundation is firmly committed to comply with the sanctions imposed by the United States. Our organization and our employees will ensure to the best of our abilities that our activities will not breach the United States sanctions. In particular, to minimize the risk of potential sanctions breaches we take the following steps before establishing any new relationship with a local partner: Comprehensive review of the ownership structure of a counterpart Screen the names of the entities, their representatives with whom we talk, their ultimate beneficial owners against the Specially Designated Nationals list of the U.S. Treasury Consult our pro bono counsel who is specialized in this topic Our Foundation has the necessary resources to comply with the reporting obligations of OFAC and we are committed to report any required activity within the prescribed time frame by OFAC. Our Foundation is committed to respect the transparency of the financial flows when dealing with its counterparts. Therefore, we will ensure to mention the relevant information on transaction orders in cases when we rely on a General License or a Specific License. If our Foundation decides to get involved in a project in a country under the U.S. comprehensive sanctions (Cuba, Iran, North Korea, Syria, and/or Crimea region), we will consult our counsel regarding the permissibility of our activities and we will document such consultation. We have an annual audit process in place to ensure no breaches go undetected. Our employees are annually trained about the implication of the United States sanction on our activities. The outside counsel provides the training on an online (or in person) set up and our employees have the chance to ask their questions. If you have any questions about our commitment to compliance, please send us an email to [email protected]