As a follow-up to a previous article, Bass, Berry & Sims attorneys Thad McBride and Cheryl Palmeri authored further details about the actions a company should take to respond to a discovered violation of U.S. sanctions. As Thad and Cheryl point out in the article, while each enforcement action is different, “a company should consider their response to an OFAC violation an opportunity to attempt to mitigate and shape the outcome. A company’s response to one OFAC violation can have an impact on any future violations.”
The full article, “OFAC Violation Response Checklist,” 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: