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Not all OFAC investigations end with Civil Monetary Penalties

New story in the Wall Street Journal today about H.B. Fuller receiving a Cautionary Letter from OFAC. The company had self-disclosed to OFAC in 2018 that some of their hygiene products may have been resold into Iran.

Always good to remember that Civil Monetary Penalties (CMPs) are actually rare. Over 90% of investigations end with a No Action Letter (which results in no further action or comment). It’s my understanding that Cautionary Letters make up the next largest batch of actions, followed by CMPs, followed by Finding of Violations – the last 2 are pretty obvious, if you just look at OFAC’s enforcement pages.

Disclaimer: I work for a unit of Dow Jones, which is the owner of the Wall Street Journal.

Categories: Cautionary Letters Enforcement Actions Iranian Sanctions


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