Screen a proposed supply against the sanctions program the lawyer names
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- From the counterparty, the country, and the goods or funds the user names, list the active OFAC program headings on the opened sanctions page that use those words, and quote the civil and criminal penalty amounts in 50 U.S.C. 1705. State that the page was not a determination that the supply is prohibited or permitted. If no heading matches, say so and return no prohibition finding.
- What the lawyer must review
- OFAC administers a number of different sanctions programs. The opened page says the sanctions can be comprehensive or selective, using the blocking of assets and trade restrictions. 50 U.S.C. 1705(a) makes it unlawful to violate, attempt to violate, conspire to violate, or cause a violation of any licence, order, regulation, or prohibition issued under the chapter. A civil penalty may not exceed the greater of $250,000 or twice the amount of the transaction. A person who willfully commits, willfully attempts, willfully conspires, or aids or abets such an act shall be fined not more than $1,000,000, or if a natural person may be imprisoned for not more than 20 years, or both. Civil and criminal proceedings must be commenced within 10 years after the latest date of the violation. The lawyer reads the program page and any licence before advising.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.