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Significant Cases and Outcomes: African Financial Institution

May 21, 2025


Representation of an African financial institution before OFAC. The bank had been publicly accused of engaging in sanctionable activity. We successfully represented the bank by gathering, assessing, and submitting exculpatory information to OFAC rebutting those allegations and helped install policies, procedures, and other remedial steps to ensure that the bank was not sanctioned.


Ferrari & Associates not only represents clients in high-profile or significant cases, it achieves results in those cases. It is often difficult to determine how OFAC will react to certain submissions or arguments. Further, it can be difficult to predict whether results can be achieved in matters pending before OFAC, given that they often rely on policies, guidance, and information that is not publicly available. Nevertheless, over the years, the OFAC lawyers at Ferrari & Associates have been able to successfully represent their clients before OFAC based on their understanding of OFAC’s procedures, policies, and legal interpretations. This success can take many forms ranging from obtaining additional information to allow a designated party to understand the true reasons behind their designation to helping a financial institution institute a sanctions compliance program.

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