OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an approximately $7.8 million civil penalty for 9,256 violations of the Global Terrorism Sanctions Regulations (“GTSR”). SITA provides telecommunications services to companies in the civilian air transport industry.  Membership in SITA is open to industry operators worldwide...