If you have an interest in OFAC enforcement actions, we recommend The Aggressive Extraterritorial Reach of US Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, in the April 16, 2020 issue of the National Law Review.
Here is the article outline:
A. Bases for OFAC jurisdiction over foreign parties.
1. US presence, including US financial system.
2. US persons.
3. US goods.
4. US ownership control.
5. Secondary sanctions, (even without a US nexus).
B. Consequences of OFAC sanctions.
C. examples of enforcement actions based upon the conduct of foreign parties.
To access the article, click here.