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ARTICLE · 15 APRIL 2011

Lessons Learned From Recent OFAC Enforcement Cases

Fried Frank Harris Shriver & Jacobson
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Recent settlements in enforcement actions involving U.S. economic and trade sanctions have increased―from roughly $5 million recovered in 2007 and 2008 to more than $1 billion in recoveries in 2009 and 2010 alone.

United StatesInternational Law
Mario Mancuso
Mario Mancuso
Michael Ginsberg
Michael Ginsberg
Jay Kraemer
Jay Kraemer

Recent Settlements Portend More Vigorous, Coordinated Enforcement of Sanctions and Heavier Penalties for Violations

Recent settlements in enforcement actions involving U.S. economic and trade sanctions have increased―from roughly $5 million recovered in 2007 and 2008 to more than $1 billion in recoveries in 2009 and 2010 alone.1 The magnitude of this increase, and the diversity of the affected parties, signals more vigorous enforcement of sanctions, particularly in the current climate where more sanctions are being adopted, more conduct is covered, and the government's enforcement efforts are more extensive, more coordinated, and better resourced.

OFAC's Economic Sanctions Enforcement Guidelines

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