RK&O Client Alert: "There's a Hole in Your Screen: Strategies for Meeting Evolving Sanctions Compliance Risks"

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April 20, 2018

Businesses are now on notice that the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) intends to use its enforcement powers to police a broad array of potential interactions and relationships with sanctioned parties that cannot reliably be captured through traditional transaction due diligence and screening protocols because they involve early stage, informal and even undocumented relationships.  In a series of decisions and guidance, OFAC has decisively confirmed it will penalize firms that fail to identify sanctioned party relationships arising during pre-transaction negotiations or involving sanctioned parties merely acting on behalf of transaction counterparties.   

In this client alert, RK&O attorneys Michael D. Mann and Jamie A. Schafer review strategies for meeting evolving sanctions compliance risks.

Click here to read the full client alert.