Jonathan Poling Quoted in Global Investigations Review on OFAC Enforcement Actions
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Akin Gump international trade partner Jonathan Poling has been quoted in the Global Investigations Review article “Corporate executives seldom face punishment in US sanctions cases.” The article reports that, while the Treasury Department’s Office of Foreign Assets Control (OFAC) is known for its tough reputation within the global business community, it has handed down just three enforcement actions against individuals over the past decade.
According to GIR, there is nothing preventing OFAC from pursuing cases against individual business executives. Bringing large enforcement cases against corporations, though, the article says, may be the most effective way to focus minds on compliance within the private sector.
Poling disagrees. “It’s unclear to me what deterrent value OFAC obtains from only enforcing sanctions cases against companies and seldom, if ever, enforcing sanctions against employees that have committed the violations,” he said.
