Bass, Berry & Sims attorneys Thad McBride and Cheryl Palmeri authored an article outlining steps a company should take to respond to a U.S. sanctions violation. Thad and Cheryl recommend the following actions:
- Implement immediate remedial actions
- Decide whether to self-disclose
- Scope the internal investigation
- Take corrective action
- Negotiate with OFAC
The full article, “Responding to an OFAC Violation,” was published by Lexis Practice Advisor® and is available in the PDF below. This article appeared as part of a series of practice notes for Lexis Practice Advisor®; other articles included: