From June through mid-September of 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published six settlements of apparent sanctions violations (Check out our previous Four Key Takeaways from OFAC Enforcement Actions to Date in 2020 covering enforcement actions up to May of 2020). Although enforcement actions are down in numbers compared to last year, those that have been published, however, are noteworthy nonetheless.
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