This is one of those questions that keep OFAC Officers up at night.Ā Due to the complexity ofĀ theĀ OFACĀ sanctions andĀ the scope of application,Ā it isĀ a challenge to create a robust program and think of everything. However,Ā with theĀ potentialĀ of fines with even one violation,Ā and the sizeĀ of fines being issued for multiple violations,Ā itĀ is imperative that financial institutions have aĀ strongĀ OFAC program.Ā AĀ strongĀ program must […]
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