On December 6, Washington, D.C. financial institutions regulation and enforcement counsel Sean Thornton spoke at the American Conference Institute's OFAC Boot Camp in New York. Mr. Thornton participated in a presentation titled "What to Do if You Suspect or Discover a U.S. Sanctions Violation: How to Structure an Internal Investigation to Mitigate Liability Risks and Implement Effective Remedial Measures." The presentation focused on when to investigate, and to what degree; special considerations for internal investigations involving a foreign subsidiary or affiliate; when to call OFAC, and when it will take over the investigation; and how to identify and implement appropriate remedial measures, including tightened systems and targeted training.