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.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.