STEPTOE: OUTSIDE COUNSEL
Recent enforcement actions by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) against exporters have brought into focus an important element of a sanctions compliance program: the ability to respond rapidly and effectively when early warnings indicate a risk of a violation. In keeping with its overall expectation of risk-based compliance, OFAC seems to take a dim view of exporters who do not react quickly to red flags.
Benefits of a rapid response
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