Part 1: As a matter OFAC: What every company should know about complying with the agency’s complicated sanctions programs

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Originally published in InsideCounsel.com on June 13, 2012.

You are sitting at your desk when you are handed an envelope that just arrived in the mail. It bears the return address of the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and it contains an administrative subpoena seeking information and documents relating to a particular transaction in which your company participated. It asks you to make this discovery production to OFAC’s Office of Enforcement within 30 days.

You may have seen news stories about extremely large civil penalties imposed on financial institutions and manufacturing companies for violations of OFAC’s sanctions programs, but if you have not dealt with OFAC before, there are several important questions that you are probably asking yourself. What is OFAC? What should you do in response to the subpoena? What are the potential consequences for your company as a result of an investigation? What can you do to ensure compliance with OFAC’s regulations or to avoid an investigation in the first place? This article answers these questions and offers a brief introduction to the subject of OFAC enforcement actions.

Please see part one of the article below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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