Tagged: OFAC Significant enforcement

OFAC 2020 Review: Enforcement Themes and Common Violations (Part II of II)

The 2020 OFAC enforcement record underscores the importance of sanctions compliance.  Yet, companies appear to move slowly in response to sanctions risks, often relying on outdated or outmoded screening technologies and failing to build basic policy controls and procedures. In reviewing the 2020 enforcement actions, many of the cases involve common miscues and compliance failures.  These cases fall into the following categories: (1) basic screening...