What a Company Risks for a Late, Inaccurate, or Incomplete OFAC Subpoena Response
When a company receives an administrative subpoena from the Office of Foreign Assets Control (OFAC), the instinct is to focus entirely on the merits: did a violation happen or not? That instinct is understandable, but incomplete. A subpoena is not only a demand to explain the past; it is an independent source of new liability, one that arises not from what happened before the subpoena, but...