OFAC Shifts Focus from Quantity to Quality

Rachel Fiorill spoke with Global Investigations Review (GIR) about shifting enforcement trends at the US Treasury Department’s Office of Foreign Assets Control (OFAC), including declining settlement numbers and fewer cases receiving voluntary self-disclosure credit. GIR’s analysis suggests OFAC is prioritizing fewer, higher-impact enforcement actions while increasingly relying on interagency referrals and whistleblower tips. Rachel, a former OFAC enforcement chief, highlighted the growing influence of the Financial Crimes Enforcement Network’s whistleblower program in generating credible investigative leads. “I do think we’re going to see a number of investigations materialize from those tips and result in public enforcement actions,” Rachel said.

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