THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 58, March 2017

No violation is too small and no connection too attenuated to escape U.S. OFAC scrutiny

It’s tempting to think that the U.S. Office of Foreign Assets Control (‘OFAC’) only has eyes for the global big boys when it comes to enforcing U.S. sanctions. But, that is far from true and..

  It’s tempting to think that the U.S. Office of Foreign Assets Control (‘OFAC’) only has eyes for the global big boys when it comes to enforcing U.S. sanctions. But, that is far from true and companies of all shapes and sizes should be aware of OFAC’s interest in even the smallest operators and transactions. By Ori Lev, Tamer Soliman, Thomas J. Delaney, Marc R. Cohen, Alex C. Lakatos, Matthew Bisanz and Simeon M. Kriesberg.   Over the past several years, Office of Foreign Assets Control (‘OFAC’) settlements in which non U.S. financial institutions have paid hundreds of millions of...

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