OUR SERVICES

Why Clarity

Clarity Compliance Consulting is a boutique sanctions advisory firm that pairs industry expertise with deep Office of Foreign Assets Control (OFAC) experience. Founded by the former Head of OFAC’s Compliance Division and the agency’s lead expert on shipping, energy, and insurance, Clarity helps companies resolve their most urgent and sensitive sanctions issues.

With Clarity, clients work directly with the people who wrote today’s sanctions rules. We understand what OFAC is really looking for in targeting and civil
enforcement investigations, and we give our clients practical, tailored advice that reflects how the agency actually works.

Your Challenges

Geopolitical shifts and sanctions divergence

Companies that once thought of themselves as “low sanctions risk” can quickly find themselves in trouble due to shifting policy winds, and sanctions regimes that seemed intractable (Syria, Venezuela, Iran, Russia) may be waived or revoked due to geopolitical changes. Some sanctions regimes have diverged among jurisdictions, creating compliance friction and conflicts of law.

OFAC enforcement focus on new industries and ten-year statute of limitations

OFAC has now imposed penalties on private equity, broker dealers, venture capital, international freight forwarders, crypto, and real estate companies. OFAC has ten years to conduct civil enforcement investigations, heightening the risks for companies that uncover apparent violations.

Drug cartels now classified as terrorists

Companies with operations or supply chains in Latin America are now exposed to additional civil and criminal risk and must make challenging decisions regarding local subsidiaries, counterparties, suppliers, and ports.

Intense pressure on shipping and energy

OFAC blocked nearly 500 vessels in 2025, and the EU and UK aggressively targeted the shadow fleet network. Maritime shipping companies, commodities traders, and insurers/reinsurers will be exposed to complex and changing sanctions risks in 2026.

Sanctions Horizon Advisory

Sanctions don't emerge without warning, but acting on early signals requires knowing how OFAC actually designs and sequences new programs. Clarity advises law firms, corporates, hedge funds, and investors on what the sanctions landscape looks like before it shifts, including war-gaming potential new regimes, stress-testing portfolios and positions against plausible scenarios, and providing ongoing horizon scanning so clients aren't caught flat-footed when policy moves. Other advisory firms can tell you what might happen in geopolitics. Clarity tells you what OFAC will do about it.

OFAC Stress Tests and Risk Assessments

Clarity offers two tiers of assessment. Our OFAC Stress Test is a focused, rapid evaluation of your
most critical exposures and your readiness to respond if OFAC came knocking today. For companies that want a more comprehensive view, our full Risk Assessment evaluates sanctions risks across business lines, jurisdictions, transactions, supply chains, and counterparties.

Investigations and Remediation

When a matter is escalating, whether triggered by an internal finding, negative media, or a regulator's request, you want people who know OFAC's enforcement process on your side. Clarity's founders know how OFAC values apparent violations, what remediation it expects to see, and how to present your case most effectively. We have led large-scale remediation efforts at international financial institutions and know what OFAC is looking for.

Gap Assessments and Control Enhancements

Sanctions regulations change faster than most compliance programs can keep up with. Clarity
identifies the gaps between where your program is and where OFAC expects it to be: not in theory
but based on direct experience with what OFAC actually scrutinizes. We then help clients close those gaps in a way that is practical for their business, not just defensible to regulators.

Customized Training

Clarity designs and delivers training built around your industry, business lines, and risks, informed by the same expertise that produced OFAC’s own guidance for the maritime, insurance, energy, and banking sectors.

Due Diligence and Deal/Transaction Review

Clarity reviews acquisitions and investments for sanctions exposure, drawing on firsthand knowledge of the evasion typologies, ownership structures, and jurisdictions that OFAC targets.

Expert Witness Services