Beyond Legal Formalities: A Discussion with Lawrence Scheinert, OFAC Associate Director for Enforcement, Compliance, and Analysis

Recorded on Thursday, June 11, 2026

In recent guidance and enforcement actions totaling hundreds of millions of dollars, OFAC has emphasized “look[ing] beyond legal formalities to underlying practical and economic realities.” The guidance and enforcement cases shine a light on the role of so-called “gatekeepers,” such as accountants, attorneys, investment advisors, and trust and corporate formation providers.

OFAC’s Lawrence Scheinert will sit down with Kharon’s Howard Mendelsohn to discuss the recent Guidance on Sham Transactions and Sanctions Evasion, enforcement actions against “gatekeepers,” and the increasing convergence of AML and sanctions compliance.

Speakers:

Lawrence Scheinert
Associate Director for Enforcement, Compliance, and Analysis,
Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury

Lawrence Scheinert is the Associate Director for Enforcement, Compliance, and Analysis at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). In this role, he oversees OFAC’s enforcement, compliance, and private sector outreach programs. Mr. Scheinert previously served as a Senior Advisor to the Treasury Department’s Under Secretary for Terrorism and Financial Intelligence and before that as the Director of the Office of Special Measures at the U.S. Financial Crimes Enforcement Network. Mr. Scheinert also previously worked as a corporate and securities associate at the international law firm of White & Case LLP. Mr. Scheinert has a degree in finance from Lehigh University, a law degree from the University of Florida, and an LL.M. in Securities and Financial Regulation from Georgetown Law.

Howard Mendelsohn
President, Global Business Development and Engagement, Kharon

Howard works closely with business, compliance, and legal professionals to strengthen programs and controls for managing risks at the intersection of global security and commerce. Howard has over two decades of experience in combating illicit financial activity in both the government and the private sector. Howard served at the U.S. Treasury Department from 2001 to 2011, including as Deputy Assistant Secretary and Assistant Secretary (Acting) for Treasury’s Office of Intelligence and Analysis. Howard led Treasury’s intelligence functions, including oversight of analytical production, risk assessment, security, and strategic planning. Following his service at Treasury, Howard held leadership positions in Enterprise Compliance at PNC Financial Services Group. He is a recognized thought leader on global security and risk matters and speaks regularly at conferences.

Andrew Sobotka
Senior Advisor, Kharon

Andrew is a senior advisor to Kharon's President of Global Business Development and Engagement. Prior to joining Kharon, Andrew served for more than five years as a Sanctions Investigator and Senior Sanctions Coordinator at the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). Before OFAC, Andrew was a David L. Boren Fellow in Poland and worked for the U.S. Department of Defense. Andrew holds a B.A. in Global Affairs and Russian and East European Studies from Yale University and an M.S. in Foreign Service from Georgetown University's School of Foreign Service.