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Office of Foreign Assets Control (OFAC) Nexus

Morrison & Foerster LLP

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

Morrison & Foerster LLP

Pay At Your Own Risk: OFAC Issues Advisory On Potential Sanctions Risks Stemming From Ransomware Payments

On Thursday, October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory highlighting potential sanctions risks associated with ransomware payments related to malicious...more

Morgan Lewis

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

Morgan Lewis on

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

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