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...
Belarus Sanctions: OFAC Lifts Restrictions on Banks and Potash Producers
On March 26, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) moved on three fronts at once. It issued General License No. 14 (GL 14), authorizing transactions with the Belarusian Bank for Reconstruction and Development, “Belinvestbank,” and its affiliates. It revoked Directive 1 under Executive Order 14038, lifting the longstanding prohibitions on dealings...
$3.77 Million Lesson: How Dealing with Sanctioned Persons Destroys Business and Reputation
On February 25, 2026, the Office of Foreign Assets Control (OFAC) announced that a U.S. individual agreed to pay $3,777,000 to settle potential civil liability for 20 apparent violations of U.S. sanctions on Syria. The case sends a clear message: even indirect managerial involvement with sanctioned persons or entities can result in severe financial and reputational consequences even years...