OFAC enforcement trends

General

OFAC 2020 Review: Enforcement Themes and Common Violations (Part II of II)

The 2020 OFAC enforcement record underscores the importance of sanctions compliance. Yet, companies appear to move slowly in response to sanctions risks, often relying on outdated or outmoded screening technologies and failing to build basic policy controls and procedures. In reviewing the 2020 enforcement actions, many of the cases involve

General

2020 OFAC Sanctions Enforcement Year in Review (Part I of II)

The pandemic and its impact is the story of 2020 – no doubt. Federal prosecutors and regulatory enforcement agencies faced unprecedented challenges. In the face of these challenges, however, enforcement almost across the board continued with some significant exceptions relating to individual criminal enforcement. Prosecutors faced almost impossible obstacles to convening