I 
118TH CONGRESS 
1ST SESSION H. R. 1164 
To require the Comptroller General of the United States to conduct a study 
with respect to outreach activities performed by the Office of Foreign 
Assets Control, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
FEBRUARY 24, 2023 
Mr. LYNCH introduced the following bill; which was referred to the Committee 
on Foreign Affairs 
A BILL 
To require the Comptroller General of the United States 
to conduct a study with respect to outreach activities 
performed by the Office of Foreign Assets Control, and 
for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘OFAC Outreach and 
Engagement Capabilities Enhancement Act’’. 
SEC. 2. FINDINGS. 
Congress finds the following: 
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(1) The Office of Foreign Assets Control is the 
United States Government agency responsible for 
administering and enforcing economic sanctions pro-
grams, primarily against countries and groups of in-
dividuals, such as terrorists and narcotics traf-
fickers. 
(2) All United States persons must comply with 
OFAC regulations, including all United States citi-
zens and permanent resident aliens regardless of 
where they are located, all persons and entities with-
in the United States, all United States incorporated 
entities and their foreign branches. In the cases of 
certain programs, foreign subsidiaries owned or con-
trolled by United States companies also must com-
ply. Certain programs also require foreign persons in 
possession of United States-origin goods to comply. 
(3) While the sanctions announcements are 
themselves notice of the requirements placed on all 
United States persons, OFAC conducts additional 
outreach through its compliance office, serving as 
OFAC’s primary liaison to the private sector and op-
erating OFAC’s public ‘‘hotline’’ for sanctions-re-
lated questions and the conduct of civil investiga-
tions for potential sanctions violations. 
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(4) While many industries, such as large multi-
national financial institutions and industrial firms, 
have sophisticated sanctions departments to manage 
compliance with the strict-liability mandates from 
OFAC and to enact practices to defend their busi-
ness’ sales and supply chains from abuse by sanc-
tions-designated bad actors, many smaller entities 
and industries, do not. 
(5) According to the U.S. Department of the 
Treasury’s 2021 Sanctions Review, ‘‘Sanctions are 
only as effective as their implementation, especially 
with regard to communication and engagement. In 
order to better calibrate the use of this tool, Treas-
ury needs to communicate and coordinate more ef-
fectively with stakeholders affected by the use of fi-
nancial sanctions. Treasury can build on existing 
outreach and engagement capabilities through en-
hanced communication with industry, financial insti-
tutions, allies, civil society, and the media, as well as 
new constituencies, particularly in the digital assets 
space.’’. 
(6) The Assistant Secretary for Terrorism and 
Financial Intelligence noted in a 2022 speech to a 
private-sector audience at the American Conference 
Institute, ‘‘We need to redouble efforts—to make 
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sure that these networks do not pass under your 
radar and around our laws, and that when you ob-
tain information about them, you promptly take ac-
tion. This is not just a matter of compliance; it is 
a moral imperative. The choice is between permitting 
and preventing sanctions evasion—there is no space 
for neutral ground here.’’. 
(7) Examples of successful, robust Federal Gov-
ernment public-private sector outreach programs 
that support the agency mission abound from the 
law enforcement, Intelligence Community, and regu-
latory agencies, such as the Federal Bureau of In-
vestigation’s InfraGard, the Public-Private Analytic 
Exchange Program from the Department of Home-
land Security and the Office of the Director of Na-
tional Intelligence, and the Financial Crime Enforce-
ment Network’s FinCEN Exchange. 
(8) The FinCEN Exchange, from OFAC’s sis-
ter agency within the U.S. Department of the Treas-
ury, was mandated on January 1, 2021, when Con-
gress enacted the Anti-Money Laundering Act of 
2020 (AML Act). Section 6103 of the AML Act es-
tablishes the FinCEN Exchange to facilitate a vol-
untary public-private information-sharing partner-
ship between law enforcement agencies, national se-
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curity agencies, financial institutions, and FinCEN 
to effectively and efficiently combat money laun-
dering, terrorism financing, organized crime, and 
other financial crimes, protect the financial system 
from illicit use, and promote national security. 
(9) The objective of FinCEN Exchange is to 
develop, deliver, and sustain innovative public-pri-
vate information sharing in order to enable the pri-
vate sector to better identify risks and provide 
FinCEN and law enforcement with critical informa-
tion to disrupt money laundering, terrorism financ-
ing, and other financial crimes. The program goals 
of the exchange are to: 
(A) Enhance communication, collaboration, 
and partnerships among FinCEN, law enforce-
ment, and financial institutions. 
(B) Support priority national security and 
counter-illicit finance investigations and poli-
cies. 
(C) Enhance the utility of suspicious activ-
ity reports and share feedback with the private 
sector. 
(D) Encourage, enable, and acknowledge a 
focus on high-value and high-impact activities. 
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