RK&O Client Alert: "OFAC Highlights Deceptive Practices by Sanctions Evaders and Suggests Heightened Due Diligence Expectations"

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March 12, 2018

As U.S. economic sanctions have tightened, sanctioned countries, entities and individuals are engaging in increasingly sophisticated practices to evade their impact.  Recent reports in the media and by U.S. regulators have described complicated sanctions evasion schemes involving false documentation, front companies and other deceptive trade practices which appear to have succeeded in luring otherwise innocent U.S. parties into prohibited transactions. 

In this client alert, RK&O attorneys Michael D. Mann and Jamie A. Schafer review recent developments and OFAC's evolving due diligence expectations.

Click here to read the full client alert.