OFAC Counsel When the Stakes Are Real
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) administers and enforces a dense, fast-moving sanctions regime that can affect ordinary commercial payments, international supply chains, financial institutions, and individuals with cross-border assets or relationships. When OFAC issues arise—whether through a blocked transfer, a bank inquiry, an internal compliance escalation, or a government investigation—there is very little room for error. Timing, precision, and a clear strategy matter.
Duncan Levin advises clients on sanctions compliance, licensing, blocked and rejected transactions, internal investigations, enforcement exposure, and related criminal or regulatory risk. He works discreetly and efficiently, with a practical understanding of how OFAC issues surface in the real world—through banks, counterparties, compliance teams, and government outreach.
What OFAC Issues Commonly Look Like
OFAC problems rarely arrive with a single, neat question. They show up as business disruption and uncertainty:
- A wire is blocked or rejected by a bank’s sanctions filter
- A counterparty is tied—directly or indirectly—to a sanctioned party or jurisdiction
- A compliance team flags a transaction, customer, shipment, or beneficial ownership concern
- A company discovers potential screening gaps or historical exposure
- An individual cannot access funds due to a blocked account or “frozen” assets
- A government inquiry raises the risk of civil penalties, criminal exposure, or reputational fallout
In these moments, the goal is not to recite regulations. The goal is to understand what happened, assess risk, preserve options, and move quickly toward a defensible resolution.
How Levin & Associates PLLC Helps
- Sanctions risk assessment and compliance counseling
- SDN and ownership/control analysis (including indirect exposure)
- Guidance on blocked vs. rejected transactions and bank compliance communications
- OFAC specific-license and interpretive guidance submissions
- “Return-to-originator” and other resolution pathways for blocked funds
- Voluntary self-disclosures and penalty mitigation strategy
- Internal investigations, document preservation, and remediation planning
- Representation in OFAC enforcement matters and parallel DOJ/regulatory inquiries
- Advising individuals and families facing blocked assets or sanctions-related restrictions
Experience That Translates to Strategy
Duncan Levin is a former federal prosecutor and former senior Manhattan District Attorney’s Office attorney with deep experience in financial enforcement and asset recovery matters, including sanctions-adjacent investigations and large-scale forfeiture work. He has been involved in matters arising from major bank enforcement actions, including those involving HSBC and Standard Chartered, and has worked on investigations involving BNP Paribas and ING.
That background matters because sanctions issues are rarely isolated. They often overlap with banking compliance, fraud investigations, money movement, asset restraint and forfeiture risk, cross-border evidence, and reputational exposure. Duncan approaches OFAC matters with that full landscape in mind.
A Practical, Client-First Approach
OFAC issues can freeze accounts, stall deals, and trigger intense internal pressure. Our focus is practical: rapid issue triage and risk mapping; clear, defensible guidance; discreet handling of sensitive matters; and a resolution strategy tailored to the client’s objectives and risk tolerance.
If a bank has blocked a payment, compliance has flagged a counterparty, or you are concerned about sanctions exposure, we can help you assess next steps and choose the most effective path forward.
