This article is the second in a series about the Office of Foreign Assets Control (OFAC). The first installment provided an introduction to the agency and its sanctions programs.
What are the potential consequences of an OFAC investigation?
How should you handle an OFAC subpoena?
An OFAC subpoena should be treated with the utmost seriousness, much as one would treat a grand jury subpoena or a subpoena from the Securities and Exchange Commission. Perhaps even more so than in these other contexts, the recipient should consider retaining an attorney with specialized knowledge of the various OFAC sanctions programs, the exceptions to the programs and the art of making a mitigation submission to OFAC in advance of an assessment of a civil penalty.