Cos. Must Meet Evolving Sanctions Compliance Challenges

Law360 (May 2, 2018, 3:27 PM EDT) -- Businesses are now on notice that the U.S. Department of Treasury's Office of Foreign Assets Control intends to use its enforcement powers to police a broad array of potential interactions and relationships with sanctioned parties that cannot reliably be captured through traditional transaction due diligence and screening protocols, because they involve early-stage, informal and even undocumented relationships.

In a series of decisions and guidance, OFAC has decisively confirmed it will penalize firms that fail to identify sanctioned party relationships arising during pretransaction negotiations, or involving sanctioned parties merely acting on behalf of transaction counterparties.

Given the amorphous nature of the interactions...

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