OFAC knows what it is – tells you so right in those pesky Enforcement Guidelines. But, in the real world, do those calls seem right?
Not if you look at the SAP enforcement action, IMHO…
OFAC Gets an E for… Egregious? looks at OFAC’s definition, and sees how it was applied in the SAP and Nordgas enforcement actions.
Which Mr. Watchlist thinks was darn screwy… let me know if you agree.