Potential benefits of cooperation with OFAC (Part 2)

Several recent examples suggest that OFAC rewards cooperating entities with mild penalties

This is Part 2 of a three-part series examining the benefits of cooperation with the Office of Foreign Assets Control (OFAC). For Part 1, click here.

As the formulas from Part 1 demonstrate, OFAC’s regulations strongly incentivize cooperation to reduce a violator’s penalty. The next section examines a few recent enforcement actions in which companies have taken advantage of these regulatory formulas to minimize penalties resulting from violations.

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Stephen A. Miller

Stephen A. Miller practices in the commercial litigation group at Cozen O'Connor's Philadelphia office. Prior to joining Cozen O'Connor, he clerked for Justice Antonin Scalia...

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Matthew A. Glazer

Matthew A. Glazer practices in the commercial litigation group at Cozen O'Connor's Philadelphia office. Mr. Glazer served as an assistant district attorney in Philadelphia for...

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Jeffrey M. Monhait

Jeffrey M. Monhait practices in the commercial litigation group at Cozen O'Connor's Philadelphia office. Mr. Monhait graduated from Haverford College and Harvard Law School.

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