• Lessons Learned from Recent OFAC Enforcement Cases
  • April 15, 2011 | Authors: Jay R. Kraemer; Mario Mancuso
  • Law Firm: Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
  • Recent settlements in enforcement actions involving U.S. economic and trade sanctions have increasedÂżfrom roughly $5 million recovered in 2007 and 2008 to more than $1 billion in recoveries in 2009 and 2010 alone.1 The magnitude of this increase, and the diversity of the affected parties, signals more vigorous enforcement of sanctions, particularly in the current climate where more sanctions are being adopted, more conduct is covered, and the government’s enforcement efforts are more extensive, more coordinated, and better resourced.