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As we mentioned in our U.S. Sanctions Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity was no exception. OFAC rolled out 30 public enforcement actions in 2019, with 26 civil penalties or settlements and four findings of violation. Eleven of the enforcement actions were directed at financial institutions (“FIs”)

Top 10 Lessons Learned from OFAC's 2019 Financial Institution Enforcement Actions (OFAC 2019 Year in Review Part 2)

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Top 10 Lessons Learned from OFAC's 2019 Financial Institution Enforcement Actions (OFAC 2019 Year in Review Part 2)