... associated with sanctions is the most pronounced for them. The purpose of the article is to fill in this gap in the literature.
Study Design
The imposition of sanctions by the U.S. Department of the Treasury and its Office of Foreign Assets Control (OFAC) is extensively
regulated
by 2009 guidelines that set several important parameters. First, the amount of the fine depends on the volume of transactions. Second, it is influenced by a number of aggravating and mitigating circumstances, the key ones ...
... to find fault with even small things and non-obvious episodes.
It should be said that the Department of the Treasury itself has done a lot of work to generalize the record of its investigations against violators. The Office of Foreign Assets Control (OFAC) has issued basic recommendations for companies, corporations and other organizations on how to control sanctions risks and
develop corporate regulatory fitness programs
. The document analyzes in detail the typical mistakes committed by businesses ...
... cases when business violates imposed sanctions for one reason or another, while governmental regulators react with punitive measures in order to change the behavior of the violators.
The U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) is a key governmental regulator, although in some cases other regulators take part in coercive actions. The Department of Justice, the Department of Commerce, the Federal Reserve System Board of Governors and other institutions may participate in ...
