OFAC Issues Interim Final Rule on Economic Sanctions Enforcement Guidelines

Download IconDownload Print IconPrint

OFAC Issues Interim Final Rule on Economic Sanctions Enforcement Guidelines

Client News
On September 2, 2008, the US Treasury Department's Office of Foreign Assets Control (OFAC) issued an interim final rule, "Economic Sanctions Enforcement Guidelines" (Guidelines), to explain its policy for determining the appropriate enforcement response to an apparent violation of US economic sanctions enforced by OFAC and the amount of any civil monetary penalty (CMP). The Guidelines became effective on September 8, 2008, when they were published in the Federal Register, and supersede OFAC's interim enforcement procedures for banking institutions (Interim Final Rule for Banks), dated January 12, 2006, and OFAC's proposed enforcement guidelines (Proposed Rule), dated January 29, 2003 (other than the proposed Appendix to the Cuban Assets Control Regulations). For more on the interim final rule, see our recent Email Alert.

Notice

Unless you are an existing client, before communicating with WilmerHale by e-mail (or otherwise), please read the Disclaimer referenced by this link.(The Disclaimer is also accessible from the opening of this website). As noted therein, until you have received from us a written statement that we represent you in a particular manner (an "engagement letter") you should not send to us any confidential information about any such matter. After we have undertaken representation of you concerning a matter, you will be our client, and we may thereafter exchange confidential information freely.

Thank you for your interest in WilmerHale.

I Accept Cancel