ANALYSIS: A New Partnership Aids OFAC Sanctions Enforcement

A new partnership between the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Delaware’s Department of Justice is an important development in U.S. economic sanctions compliance. Lawyers should note that the enhanced collaboration and information-sharing from this deal may signal more active and aggressive U.S. sanctions enforcement to follow.

Economic sanctions regulations have never been a back-burner issue in the U.S., not even during the unprecedented challenges of the Covid-19 pandemic. OFAC, which enforces U.S. sanctions, has kept busy issuing sanctions-related regulations and guidance and reaching settlements in various enforcement actions.

But OFAC’s memorandum of understanding ...