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Knowledge of Wrongdoing the Biggest Factor for Maximum OFAC Penalties, Says Director

When Congress enacted a law last year that increased the potential penalties for violating economic sanctions by five-fold, financial institutions had one question: how would the new penalty powers be used? Now, following the publication of economic sanctions enforcement guidelines on September 8, an answer has come: big fines will be applied sparingly, according to Adam Szubin, director of the U.S. Treasury Department's Office of Foreign Assets Control. Maximum penalties-which can potentially be millions of dollars-will be levied only against the violators that knew they were breaking the law, he said. Szubin, who formerly served as senior advisor in the...

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