Recent OFAC Actions
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OFAC has issued a Revised Interim Policy  with respect to Civil Penalties to explain how it will handle enforcement cases in which a Prepenalty Notice was issued after October 16, 2007 (the date of enactment of the International Emergency Economic Powers Enhancement Act) but before September 8, 2008 (the date of publication of OFAC's new Economic Sanctions Enforcement Guidelines). The Revised Interim Policy also addresses cases in which OFAC staff agreed to recommend a proposed settlement amount internally, and that amount was memorialized in writing between the parties between October 16, 2007, and September 8, 2008. The Revised Interim Policy supplements the Civil Penalties - Interim Policy posted on OFAC's website on November 27, 2007.
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