This is one of those questions that keep OFAC Officers up at night. Due to the complexity of the OFAC sanctions and the scope of application, it is a challenge to create a robust program and think of everything. However, with the potential of fines with even one violation, and the size of fines being issued for multiple violations, it is imperative that financial institutions have a strong OFAC program. A strong program must […]
2020: The Year of Acting Unilaterally
A core tenet of economic sanctions is that they are more effective when they are imposed multilaterally, as that presents fewer alternatives for the targeted parties to continue their sanctioned activities. The past year, however, has shown few, if any, attempts at coordinated action. In fact, if anything, 2020 was more of a year in […]