The web of U.S. sanctions across the globe is dynamic and complex, and it can affect companies doing business in any corner of the world, even those with limited ties to the United States. Through the Office of Foreign Assets Control (OFAC), which administers and enforces civil violations of those sanctions, and the Department of Justice (DOJ), which enforces willful sanctions violations under U.S. criminal law, the U.S. government extends its reach to economic activity around the world. Companies and individuals can unexpectedly find themselves facing significant penalties, including fines, restrictions on conducting business with the United States, seizure of their assets, and criminal process, as recent enforcement efforts demonstrate.
Even inadvertent sanctions violations that are voluntarily disclosed to the U.S. government can be considered “egregious” and subject violators to significant fines. In this climate, counsel for companies that do business with, and in close proximity to, sanctioned individuals, corporate entities, and countries should be aware of the global reach of U.S. sanctions.
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