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.