In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC have provided helpful guidance to alert companies where risks are likely to increase. Sanctions enforcement involves a mix of civil and criminal line drawing. On the civil side, OFAC has explained that sanctions violations can be found based on strict liability with…
By: The Volkov Law Group
By: The Volkov Law Group
