Lessons Learned From OFAC's 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and delays due to the coronavirus pandemic. In 2020, OFAC issued 17 enforcement actions with a total of $23.6 million in penalties, compared to the 30 enforcement actions with almost $1.3 billion in penalties in 2019. The reduced numbers last year are likely due to the lack of any blockbuster cases in 2020 like the $657 million penalty against Standard Chartered in 2019 or the $100 million penalty against ZTE Corp. in 2017. Despite the absence of any huge penalties, many of OFAC's 2020 enforcement actions were groundbreaking and filled with important lessons from OFAC for those paying attention. Fortunately, we've collected those lessons for you below.