Since the terrorism attacks of September 11, 2001, grantmakers and other charitable organizations have become quite familiar with the work of the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) in the area of anti-terrorism concerns. OFAC has been
one of the key U.S. government agencies seeking to shut down terrorism funding around the world and, in conducting that activity, has focused considerable attention on charities. Such
attention has been controversial and criticized, but undoubtedly has resulted in international charities devoting more efforts to OFAC compliance. In general, OFAC's sanctions programs can be conveniently divided into two major types: (1) country-based programs, which restrict a broad range of activities in or with a specific country and its government, and (2) list-based programs, which forbid any transactions
with specific, named entities and individuals (collectively referred to as "persons").
Part of 2009 Annual Meeting Program Materials for Session 310.
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