OFAC Settlement Highlights Importance of Proactive Compliance Monitoring
By SCOTT FLICKER, KEVIN PETRASIC, AND AMANDA JABOUR
The client alert discusses a recent settlement involving the U.S. Treasury Department's Office of Foreign Assets Control (OFAC). The alert notes that the settlement has clear implications for companies engaging in cross-border transactions subject to U.S. jurisdiction. In particular, the scope of the OFAC and related investigations and the amount of the civil money settlement (representing the largest civil penalty settlement ever by OFAC) underscore the importance to financial firms and other companies with significant cross-border activities of integrating an effective OFAC compliance program into their operations and enterprise-wide compliance policies and procedures.