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ARTICLE · 24 DECEMBER 2020

OFAC Will See You Now

Your company may face increased likelihood of sanctions investigation and enforcement following the unprecedented MOU signed between the Office of Foreign Assets Control and the Delaware...

United StatesInternational Law

Your company may face increased likelihood of sanctions investigation and enforcement following the unprecedented MOU signed between the Office of Foreign Assets Control and the Delaware Department of Justice. Whether it's scrutiny from the feds or the state or both, the question is: Are you prepared?

The September Memorandum of Understanding (MOU) entered into between the U.S. Office of Foreign Assets Control (OFAC) and the Delaware Department of Justice (DOJ) could be a game changer for both domestic and foreign corporations

The MOU appears to be the first of its kind ever entered into between OFAC and a state law enforcement agency. (Previous OFAC MOUs concerned primarily federal and state banking and financial service regulators.) As such, it appears that OFAC and the State of Delaware are gearing up to increase scrutiny of entities registered in Delaware.

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