On 16 February, an article from Clyde & Co looks at the results of our in-depth analysis of OFAC penalties for sanction violations and suggests some factors that companies should take account of when considering sanction-related risks. The analysis examined over 80 OFAC sanction violation settlements made between 2009 and January 2021 to identify some of the key learning points for any company that is exposed to sanctions risk. The findings include that over one-third of all cases involved penalties imposed on the parent organisation resulting from the activities of its subsidiaries or affiliates, almost half of all cases involved organisations that had failed to heed previous warnings or alerts, and the financial services sector accounted for almost half the cases (48%) whilst engineering (7%), manufacturing (5%), technology (8%) and shipping (7%) also had a small handful of cases. It also found that in 94% of cases the introduction of stronger and more robust compliance measures was viewed favourably and credit was given to those organisations that already had a strong compliance program in place prior to the OFAC investigation.
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