Lessons From OFAC's 1st Public '50 Percent Rule' Penalty
Law360, New York (February 21, 2016, 8:45 PM EST) -- The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces economic sanctions on behalf of the United States. Until recently, the work of this small agency housed in the Treasury Building Annex was shrouded in mystery to all but a handful of specialists. Today, a majority of attorneys are at least familiar with the concept of economic sanctions. This understanding of sanctions is largely the result of media attention given to policy and regulatory changes, in addition to coverage of massive monetary penalties for noncompliance. News reports covering developments in Iran, Syria, North Korea, Russia and Cuba frequently refer to U.S. sanctions imposed upon those countries....
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