Bill joins Cozen O'Connor's Seattle office as a member of the Commercial Litigation Department.
OFAC does not deal only with cooperating entities, of course. On one hand, non-cooperating entities certainly run a risk that OFAC will refer their violations to criminal authorities. But even a non-cooperator can receive benefits, even grudgingly, under OFAC’s administrative-penalty regime — especially compared to companies that become targets of criminal prosecution and the severe penalties attendant to that process. That comparison between administrative and criminal punishments of non-cooperating entities, as discussed infra, may yield useful, persuasive data to criminal defense lawyers representing an entity under criminal investigation.
Jason Cabrera reviews President Obama's order to the Department of Labor to modernize overtime rules and how it may impact employers.