On November 9, 2009, the Office of Foreign Assets Control (OFAC)
of the U.S. Department of the Treasury issued its Economic
Sanctions Enforcement Guidelines. While the guidelines adopt in
large measure an interim final rule issued by OFAC on September 8,
2008, they represent the first final rule published by OFAC, which
deals with generally applicable economic sanctions enforcement
guidelines.
Background on Economic Enforcement Sanctions Guidelines
OFAC administers and enforces economic sanction programs against
targeted foreign countries (countries currently subject to U.S.
sanctions include Burma, Cuba, Iran and North Korea), regimes,
terrorists and terrorist organizations, and others as dictated by
U.S. policy interests. The goal of these sanctions programs is to
deprive targeted entities of the use of assets that are subject to
U.S. jurisdiction and of access to the U.S. financial system and
markets. A primary tool in enforcing these programs is through
civil
