Andrew C. Erskine Authored “Cross-Border Businesses Beware: An Incomplete OFAC Response Can Create Additional Liability,” Published in Global Trade

“As a recent OFAC enforcement action demonstrates, sanctions investigations can generate a second enforcement problem for a company due to its own deficient response. 

Bottom line: Businesses facing sanctions inquiries should assign responsibility for investigating the underlying transaction and validating the response. Before an officer signs a certification, counsel should be able to explain the factual inquiry supporting each answer.”

To view the full article as published by Global Trade, click here.