Associate Director, Office of Compliance and Enforcement

Department of the Treasury
  • Location
    Washington, D.C.
  • Sector
  • Experience
    Mid Career / Advanced
  • Apply by
  • Posted
    May 02

Position description

The Associate Director, Office of Compliance and Enforcement, heads a major component of the Office of Foreign Assets Control (OFAC). The incumbent reports through the Deputy Director to the Director of OFAC, who in turn reports directly to the Under Secretary, Office of Terrorism and Financial Intelligence (TFI). OFAC acts under the President's national emergency powers and authority granted by specific legislation to implement the nation's economic sanctions by imposing controls on financial and trade transactions, enforcing those controls, and freezing foreign assets under U.S. jurisdiction.

The incumbent leads the OFAC Sanctions Compliance & Evaluation Division and the OFAC Enforcement Division, each headed by an Assistant Director. The incumbent supports the Director and Deputy Director by implementing and enforcing compliance with economic sanctions in a manner consistent with U.S. national security and foreign policy goals and applicable laws.

The incumbent directs the enforcement of OFAC's sanctions programs through the investigation of potential sanctions violators and the levying of civil monetary penalties against those entities found to be violating sanctions. This position provides strategic direction and management and serves as the public interface for all of OFAC's enforcement activities. In this capacity, the incumbent is the primary official responsible for investigating apparent violations of U.S. economic sanctions and recommending and implementing appropriate enforcement responses including no action, cautionary letters, criminal referrals and civil penalties. The incumbent establishes standards, methods, practices, policies, and procedures for investigations as conducted by OFAC's Enforcement Division and OFAC’s Sanctions Compliance & Evaluation Division through the Assistant Directors for those divisions. The incumbent's subordinate divisions also serve as liaison and support to other U.S. law enforcement and regulatory agencies. 

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1. The Associate Director develops and implements OFAC sanctions enforcement standards, methods, practices, policies, and procedures, managing and supervising two Assistant Directors (for the Enforcement Division and for the Sanctions Compliance & Evaluation Division) whose subordinate staffs conduct enforcement investigations, issue administrative subpoenas, and take enforcement action with respect to apparent violations of U.S. sanctions laws and regulations. Incumbent reviews recommended enforcement actions and works closely with the Office of Chief Counsel (Foreign Assets Control) to ensure legal sufficiency. Incumbent reviews recommended referrals for criminal prosecution and supports criminal prosecutions at all stages, including the preparation and provision of expert testimony by OFAC Investigators or Officers in support of agencies prosecuting criminal sanctions related cases. 

2. The Associate Director exercises management authority over the analysis, assessment, processing, and resolution of all civil monetary penalty and settlement actions by OFAC. The Associate Director oversees, develops, and ensures the uniform and effective application and utilization of OFAC's Enforcement Guidelines to ensure an appropriate agency response to sanctions violations. The incumbent further oversees the collection and debt management of OFAC settlements and civil monetary penalties, which can exceed fees of several million dollars annually. The Associate Director oversees the Office's issuance of administrative subpoenas, cease and desist orders, cautionary letters, and blocking notices, as well as the preparation, vetting, and issuance of OFAC pre-penalty notices, findings of violation, and penalty notices, and the negotiation of settlement agreements. The Associate Director signs and issues OFAC pre-penalty notices and prepares and oversees penalty notice or settlement agreement packages for the Director's approval. These functions require significant coordination with the Office of Chief Counsel (Foreign Assets Control) and, when required, with the U.S. Justice Department. They also require significant coordination with senior leaders of other OFAC or Treasury Department offices and effective representation of the Office of Compliance and Enforcement in high-level meetings with other government agencies or foreign governments (particularly in the case of joint law enforcement matters or investigations), the private sector, and various industry groups. In addition, the incumbent oversees the proper disclosure of recent OFAC enforcement actions through public announcements on OFAC's Web site and other media. 

3. The incumbent works to develop and implement the standards, methods, practices, policies and procedures governing all aspects of OFAC's liaison with law enforcement agencies which support sanctions enforcement or exercise sanctions- or export control-related jurisdiction. This includes providing support for U.S. prosecutions and other domestic law enforcement efforts related to sanctions enforcement. The incumbent works with high-ranking representatives of the Department of Justice and U.S. Attorney's Offices throughout the country, the FBI, Immigration & Customs Enforcement, Customs and Border Protection, the Bureau of Industry and Security at the Commerce Department, the U.S. Secret Service, the Drug Enforcement Administration, and IRS/CI on matters related to sanctions enforcement. In cooperation with these agencies, the incumbent protects and promotes OFAC's enforcement equities while developing mutually productive and cooperative relationships. The incumbent facilitates the appropriate flow of information among, and provision of training to, U.S. enforcement and intelligence agencies, located throughout the country, on sanctions matters. The incumbent is also responsible for coordinating efforts within OFAC and among U.S. Government agencies to proactively search for, identify, and secure blocked assets.

4. The incumbent provides management supervision to the Assistant Director, Sanctions Compliance & Evaluation, who is responsible for providing sanctions compliance advice to the U.S. public at large as well as to foreign institutions. The Assistant Director and staff provide compliance advice on a daily basis to financial institutions, the trade and services community, and other U.S. businesses and individuals. This includes advice over a toll-free OFAC hotline that averages 325-350 calls per day. The Division uses sophisticated communications technology to participate in web casts and teleconferencing worldwide and also participates in numerous outreach events throughout the country.

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