Recent settlement highlights need for OFAC diligence - .PDF file.
The Office of Foreign Assets Control (OFAC) recently entered into a settlement agreement with a European-based asset manager for an alleged violation of US sanctions against Iran. The settlement agreement follows the announcement of a number of new measures that significantly expand US sanctions against Iran. What is significant about the new measures is that they explicitly target certain activities of non-US companies as well as US companies.
Click on the link above to download this Dechert briefing.