Author: Morrison & Foerster
Published: February 17th
Original Source Link
The following client alert is courtesy of CGCC
member Morrison Foerster. This resource does not, and is not intended to
constitute legal advice.
As we previously wrote in our OFAC 2020 Year in Review, the
U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw
a drop in enforcement activity in 2020, likely due to the massive year it had
in 2019 and delays due to the coronavirus pandemic. In 2020, OFAC issued 17
enforcement actions with a total of $23.6 million in penalties, compared to the
30 enforcement actions with almost $1.3 billion in penalties in 2019. The
reduced numbers last year are likely due to the lack of any blockbuster cases
in 2020 like the $657 million penalty against Standard Chartered in
2019 or the $100 million penalty against ZTE Corp. in
2017. Despite the absence of any huge penalties, many of OFAC’s 2020
enforcement actions were groundbreaking and filled with important lessons from
OFAC for those paying attention. Fortunately, we’ve collected those lessons for
you below.
For any questions, kindly contact Jiang Liu, jiangliu@mofo.com
