Tagged: OFAC Internal Controls

OFAC Enforcement and “Screening Errors” (Part I of III)

OFAC Enforcement and “Screening Errors” (Part I of III)

Here is another profound grasp of the obvious (for which I have a knack for delivering) – compliance and legal professionals can learn a number of lessons from individual enforcement actions.  In many cases, however, there is much more to the story than the headline or the list of so-called lessons learned. One category of enforcement actions is a perfect example – OFAC has brought...