General
OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions
Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front. Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions program against Russia. On its face this effort is more than Herculean, given the need to coordinate