1. OFAC 101 U.S. Sanctions Demystified

4. 1. Context

9. A Terrible Remedy? U.S. sanctions have inspired controversy since their earliest use (political cartoon ridiculing 1807 Embargo Act)

12. 2. OFAC Sanctions Today

13. OFAC Organization Adam Szubin Director Barbara Hammerle Deputy Director John Smith Associate Director Office of Program Policy and Implementation John Battle (Acting) Associate Director Office of Resource Management Bob McBrien Associate Director Office of Global Targeting Ori Lev Associate Director Office of Enforcement Dennis Wood Assistant Director Compliance Outreach and Implementation Division Andrea Gacki Assistant Director Licensing Division Rochelle Stern Assistant Director Policy Division Annette Patterson Assistant Director Budget/HR Division Marshall Fields Assistant Director Compliance Outreach and FOIA/Disclosure Division Cathleen Einstein (Acting) Assistant Director Compliance Outreach and Sanctions Support Division Michael Swanson Assistant Director Global Counter Narcotics Division Carlton Greene Assistant Director Trans-National Threats Division Michael Geffroy Assistant Director Enforcement Division I Elton Ellison Assistant Director Enforcement Division II Luke Ballman Congressional Liaison As of 24 February 2010 Stuart A. Levey Under Secretary Office of Terrorism and Financial Intelligence Office of the Chief Counsel Foreign Assets Control Advises OFAC

14. OFAC Compliance Adam Szubin Director Barbara Hammerle Deputy Director John Smith Associate Director Office of Program Policy and Implementation John Battle (Acting) Associate Director Office of Resource Management Bob McBrien Associate Director Office of Global Targeting Ori Lev Associate Director Office of Enforcement Dennis Wood Assistant Director Compliance Outreach and Implementation Division Andrea Gacki Assistant Director Licensing Division Rochelle Stern Assistant Director Policy Division Annette Patterson Assistant Director Budget/HR Division Marshall Fields Assistant Director Compliance Outreach and FOIA/Disclosure Division Cathleen Einstein (Acting) Assistant Director Compliance Outreach and Sanctions Support Division Michael Swanson Assistant Director Global Counter Narcotics Division Carlton Greene Assistant Director Trans-National Threats Division Michael Geffroy Assistant Director Enforcement Division I Elton Ellison Assistant Director Enforcement Division II Luke Ballman Congressional Liaison As of 24 February 2010 Stuart A. Levey Under Secretary Office of Terrorism and Financial Intelligence Office of the Chief Counsel Foreign Assets Control Advises OFAC

16. OFAC Licensing Adam Szubin Director Barbara Hammerle Deputy Director John Smith Associate Director Office of Program Policy and Implementation John Battle (Acting) Associate Director Office of Resource Management Bob McBrien Associate Director Office of Global Targeting Ori Lev Associate Director Office of Enforcement Dennis Wood Assistant Director Compliance Outreach and Implementation Division Andrea Gacki Assistant Director Licensing Division Rochelle Stern Assistant Director Policy Division Annette Patterson Assistant Director Budget/HR Division Marshall Fields Assistant Director Compliance Outreach and FOIA/Disclosure Division Cathleen Einstein (Acting) Assistant Director Compliance Outreach and Sanctions Support Division Michael Swanson Assistant Director Global Counter Narcotics Division Carlton Greene Assistant Director Trans-National Threats Division Michael Geffroy Assistant Director Enforcement Division I Elton Ellison Assistant Director Enforcement Division II Luke Ballman Congressional Liaison As of 24 February 2010 Stuart A. Levey Under Secretary Office of Terrorism and Financial Intelligence Office of the Chief Counsel Foreign Assets Control Advises OFAC

18. OFAC Global Targeting Adam Szubin Director Barbara Hammerle Deputy Director John Smith Associate Director Office of Program Policy and Implementation John Battle (Acting) Associate Director Office of Resource Management Bob McBrien Associate Director Office of Global Targeting Ori Lev Associate Director Office of Enforcement Dennis Wood Assistant Director Compliance Outreach and Implementation Division Andrea Gacki Assistant Director Licensing Division Rochelle Stern Assistant Director Policy Division Annette Patterson Assistant Director Budget/HR Division Marshall Fields Assistant Director Compliance Outreach and FOIA/Disclosure Division Cathleen Einstein (Acting) Assistant Director Compliance Outreach and Sanctions Support Division Michael Swanson Assistant Director Global Counter Narcotics Division Carlton Greene Assistant Director Trans-National Threats Division Michael Geffroy Assistant Director Enforcement Division I Elton Ellison Assistant Director Enforcement Division II Luke Ballman Congressional Liaison As of 24 February 2010 Stuart A. Levey Under Secretary Office of Terrorism and Financial Intelligence Office of the Chief Counsel Foreign Assets Control Advises OFAC

20. OFAC Enforcement Adam Szubin Director Barbara Hammerle Deputy Director John Smith Associate Director Office of Program Policy and Implementation John Battle (Acting) Associate Director Office of Resource Management Bob McBrien Associate Director Office of Global Targeting Ori Lev Associate Director Office of Enforcement Dennis Wood Assistant Director Compliance Outreach and Implementation Division Andrea Gacki Assistant Director Licensing Division Rochelle Stern Assistant Director Policy Division Annette Patterson Assistant Director Budget/HR Division Marshall Fields Assistant Director Compliance Outreach and FOIA/Disclosure Division Cathleen Einstein (Acting) Assistant Director Compliance Outreach and Sanctions Support Division Michael Swanson Assistant Director Global Counter Narcotics Division Carlton Greene Assistant Director Trans-National Threats Division Michael Geffroy Assistant Director Enforcement Division I Elton Ellison Assistant Director Enforcement Division II Luke Ballman Congressional Liaison As of 24 February 2010 Stuart A. Levey Under Secretary Office of Terrorism and Financial Intelligence Office of the Chief Counsel Foreign Assets Control Advises OFAC

24. Sanctions Policymaking/Coordination President of the United States Treasury Department National Security Council State Department OFAC Homeland Security Law Enforcement Commerce Department Justice Department Intelligence Community Financial Regulators FBI Policy Program Coordination

27. Frozen Assets

39. 3. OFAC Compliance & Enforcement Judith A. Lee