Rethinking Sanctions Efficiency

... taken by OFAC and by a person/company under investigation. Most of these outcomes can be formalized in a binary 1\0 code. To test the hypotheses, the behavior of businesses has been operationalized in a number of variables. Hypothesis 1 claims that a business acts rationally to break the sanctions rules. The main way to check this is to see whether OFAC identifies violations as willful or not. A willful violation would mean that a company had an initial plan to violate the regulations. Other variables include the following questions: Did the company attempt to conceal violations? Was it a regular ...