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In 2007, Congress significantly increased the arsenal of the Office of Foreign Assets Control (OFAC) for combatting violations of U.S. economic sanctions. Companies that engage in international transactions—and thus risk doing business with a potentially sanctioned country, entity or individual—should take heed of the trends that have emerged since that arsenal went live in 2009. Most importantly, it is critical that upon learning of a violation, a company retain counsel, conduct an investigation and self- report to OFAC as soon as practicable.

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