Litigation: OFAC enforcement—A look at the numbers

As penalties for U.S. economic sanction climb, how a company responds when a violation arises and its size and level of sophistication matter greatly

In 2007, Congress significantly increased the arsenal of the Office of Foreign Assets Control (OFAC) for combatting violations of U.S. economic sanctions. Companies that engage in international transactions—and thus risk doing business with a potentially sanctioned country, entity or individual—should take heed of the trends that have emerged since that arsenal went live in 2009. Most importantly, it is critical that upon learning of a violation, a company retain counsel, conduct an investigation and self- report to OFAC as soon as practicable.

The U.S. economic sanctions penalty scheme

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Tammy Bieber

Tammy P. Bieber is a partner in Tannenbaum Helpern Syracuse & Hirschtritt LLP’s Litigation & Dispute Resolution Practice, focusing on securities enforcement, government and internal...

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Vincent Syracuse

Vincent J. Syracuse is Chair of Tannenbaum Helpern Syracuse & Hirschtritt LLP’s Litigation & Dispute Resolution Practice. He represents a variety of clients in commercial...

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Paul Sarkozi

Paul D. Sarkozi is partner in Tannenbaum Helpern Syracuse & Hirschtritt LLP’s Litigation & Dispute Resolution Practice. Recently, Paul was named as one of the...

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Richard Trotter

Richard W. Trotter is an associate in Tannenbaum Helpern Syracuse & Hirschtritt LLP’s Creditors’ Rights & Business Reorganizations Practice. He focuses on complex bankruptcy and...

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