Facilitation, Foreign Subsidiaries, and OFAC Licensing
Maybe it’s because I will be discussing it at this week’s American Conference Institute 2012 OFAC Boot Camp, but the…
The 800 lb. Gorilla in the Room: OFAC and Facilitation
There is one word that makes practitioners before the United States Department of the Treasury’s Office of Foreign Assets Control…
Facilitation Under OFAC Administered Sanctions Programs
One of the least understood and most confusing concepts for those dealing with matter before the United States Department of…
OFAC Releases April Penalties Information
The United States Department of the Treasury Office of Foreign Assets Control (OFAC) has released a new announcement describing recent…