OFAC Enforcement: The Epsilon Case and Third Party Risks
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. (Here). This case requires a theme song and there is none better than Truckin (here) from Grateful Dead’s second compilation album — What a Long Strange Trip its Been. This case involved two separate OFAC investigations for violations of the Iran Sanctions Program, an appeal to...