Cozen O’Connor: Potential benefits of cooperation with OFAC (Part 3) [InsideCounsel]

Potential benefits of cooperation with OFAC (Part 3) [InsideCounsel]

This is Part 3 of a three-part series examining the benefits of cooperation with the Office of Foreign Assets Control (OFAC). To read the full article, including all three parts, click here

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.

To read part 3 of the series, click here


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Matthew A. Glazer

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