07
Jan
Overview
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced an $11.5 million settlement of an enforcement action against a U.S.-based private equity and infrastructure investment firm (the firm) for violations of U.S. sanctions in connection with an investment indirectly backed by a sanctioned individual. The action provides important guidance on OFAC’s expectations regarding ownership, control, and indirect involvement by sanctioned persons, as well as the limits of relying on outside counsel when material facts are not...