OFAC Enforcement Trends In 2017: Exporters On Notice

Law360, New York (January 8, 2018, 3:53 PM EST) -- Even as 2017 was a year of constant changes in U.S. sanctions laws, the U.S. Treasury Department’s Office of Foreign Assets Control has remained steadfast in its enforcement of existing measures, especially as they apply to export transactions. OFAC has broadened both the scope of its potential targets and its theories of liability: 2017 saw a marked increase in actions targeting non-U.S. companies, and several of those actions were based upon novel interpretations of OFAC’s regulations and jurisdictional reach. This focus on export transactions departs from...
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