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OFAC is changing how it calculates penalties in US sanctions investigations involving multiple enforcement agencies. Previously, companies have paid OFAC’s fines to other federal agencies in multi-agency settlements, and these were credited by the Treasury. Now, the Treasury will only give credit to fines paid to other agencies for sanctions violations which would also give rise to an OFAC penalty...
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Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human...
United States