Last Thursday, January 31, the U.S. Treasury Department's
Office of Foreign Assets Control (OFAC) issued its first
enforcement action of 2019, a fascinating case involving false
eyelashes that teaches that virtually any company in any
industry selling any product can find itself in OFAC's
cross-hairs (pun intended). This year also marks a decade since
OFAC published its tried-and-true Enforcement Guidelines, which outline the
agency's standard operating procedure for reviewing and
enforcing violations of U.S. economic sanctions.
Last week's case involving e.l.f. Cosmetics, like another half dozen OFAC
enforcement cases resolved over the past several months, serves as
yet another indication that OFAC has, with relatively little
fanfare, embarked upon one of the most sweeping elaborations of its
enforcement policy since its Enforcement Guidelines were published
a decade ago. Few have paid attention to the lessons from these
recent cases. You should.
