A Dramatic 6 Months For OFAC Sanctions Enforcement

By Ama Adams, Brendan Hanifin and Emerson Siegle (June 28, 2019, 3:00 PM EDT) -- Through the first half of 2019, the U.S. Department of the Treasury's Office of Foreign Assets Control strengthened country-based sanctions programs, including those targeting Venezuela and Cuba, and netted over $1.2 billion in civil penalties. Perhaps more significant, OFAC published sanctions compliance program guidance and suggested enhanced compliance program expectations through a string of recent enforcement actions....

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