Stephen A Miller Matthew A Glazer Jeffrey M Monhait

January 22, 2014 | Inside Counsel

Non-cooperating entities certainly run a risk that OFAC will refer their violations to criminal authorities. But even a non-cooperator can receive benefits under OFACs administrative-penalty regime.

By Stephen A. Miller, Matthew A. Glazer, Jeffrey M. Monhait

4 minute read

December 23, 2013 | Inside Counsel

This section examines a few recent enforcement actions in which companies have taken advantage of regulatory formulas to minimize penalties resulting from violations.

By Stephen A. Miller, Matthew A. Glazer, Jeffrey M. Monhait

4 minute read

November 20, 2013 | Inside Counsel

Recent settlements in civil enforcement proceedings brought by the Office of Foreign Assets Control (OFAC) suggest that cover-ups, not crimes, may invite the stiffest penalties.

By Stephen A. Miller, Matthew A. Glazer, Jeffrey M. Monhait

8 minute read