A Dramatic 6 Months For OFAC Sanctions Enforcement

Law360 (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.

These steps may presage continued, aggressive enforcement going forward, particularly for parties whose compliance programs do not meet OFAC’s newly articulated expectations.

Regulatory Developments

Venezuela

During 2018, the Trump administration laid the groundwork for a significant expansion of sanctions targeting Venezuela, through the issuance...

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