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OFAC Enforcement Lawyers

An OFAC Enforcement Investigation or Penalty can Cripple Your Business, Our OFAC Lawyers can Prevent that from Happening

If OFAC is investigating a potential violation of one of its sanctions programs, it will send out an administrative subpoena. An OFAC administrative subpoena seeks to obtain disclosure of information on specific transactions or on a category of transactions that might implicate OFAC-administered sanctions programs. OFAC has the legal authority to require U.S. persons to disclose this information and to impose penalties and other consequences for violations of the U.S. sanctions programs it administers. Gathering and assessing the underlying facts of the transactions which OFAC is investigating, preparing the response to OFAC's administrative subpoena, and crafting arguments for a mitigated enforcement response consistent with OFAC’s Enforcement Guidelines, all require the expertise of seasoned OFAC lawyers. Failure to properly prepare and respond to such investigations can have devastating consequences for the party being investigated, including the imposition of massive penalties and other consequences.

Ferrari & Associates has recently defended parties in the following types of OFAC enforcement matters:

  • Representation of a foreign financial institution in OFAC enforcement investigations for apparent violations of various sanctions programs. Certain of those investigations were closed out with Cautionary (warning) Letters.
  • Representation of freight forwarders in OFAC investigations of apparent violations of the Iranian Transactions and Sanctions Regulations. Certain of those investigations were closed out with Cautionary (warning) Letters.
  • Representation of a web development company in an OFAC investigation of apparent violations of the Iranian Transactions and Sanctions Regulations.
  • Representation of a social media company in an OFAC investigation of apparent violations of the Iranian Transactions and Sanctions Regulations. Case resulted in a Cautionary (warning) Letter.
  • Representation of a U.S. Citizen who owned and operated a medical device distribution company in Iran. Case resulted in a Cautionary (warning) Letter.
  • Representation of numerous U.S. companies employing persons in Iran. All resulted in Cautionary (warning) Letters.
  • Representation of U.S. citizens investigated for Russia sanctions violations due to their provision of services to Crimea. Resulted in a Cautionary (warning) Letter.
  • Representation of a U.S. bank in OFAC investigation and response to administrative subpoena for violations of the Ukraine-related-Russia sanctions. Case resulted in a Cautionary (Warning) Letter.
  • Representation of a U.S. corporation for having Iranian owners. Case resulted in a Cautionary (warning) Letter.