OFAC investigation involving Iran and Russia-related sanctions resolved with warning letter
Situation:
A U.S.-headquartered multinational company became the subject of an OFAC enforcement investigation involving apparent violations of the Iran and Ukraine-/Russia-related sanctions programs. The matter required immediate legal analysis, internal review, and strategic engagement with OFAC regarding transactions and conduct potentially implicating multiple sanctions regimes.
Stakes:
The investigation created substantial regulatory and operational exposure, including the possibility of civil penalties, expanded enforcement scrutiny, reputational harm, and increased compliance obligations across international operations. The matter also required careful management of internal reporting, transaction analysis, and remediation considerations tied to cross-border business activity.
Result:
Ferrari & Associates represented the company throughout the OFAC enforcement investigation, including regulatory submissions, factual analysis, and engagement with the agency regarding the apparent sanctions issues. The matter was ultimately resolved through the issuance of a warning letter, with no further enforcement action taken by OFAC.
