OFAC Boot Camp

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.