Resolving OFAC Subpoena for a Client in the Goods Sale Sector

Client Type and Situation:
A client involved in the sale of goods sector received an administrative subpoena from OFAC, raising concerns about potential sanctions violations related to their business transactions. The subpoena demanded a comprehensive review of their financial and operational documentation, putting the client's

business under significant scrutiny.

Approach and Research:
Upon being hired, our team immediately sought an extension of time from OFAC to allow for a thorough investigation and response preparation. Once granted, we meticulously reviewed the client's case, analyzing all relevant documents, including transactions, bank statements, power of attorney records, shipping documents, invoices, and purchase agreements. Our goal was to ensure that every aspect of the client’s business dealings was accurately represented and explained.

Steps Undertaken:
We drafted a comprehensive narrative that provided detailed answers to each of the questions outlined in the subpoena. This included an in-depth explanation of all business transactions, supported by carefully organized exhibits, translations, and relevant documentation compiled according to OFAC standards. The response package was meticulously assembled, ensuring it met all regulatory requirements, and was submitted to the OFAC officer within the established deadlines.

Outcome:
OFAC reviewed the submission over a period of four months. During this time, no additional questions or requests for further evidence were made, indicating that the response was both complete and satisfactory. Ultimately, OFAC issued a cautionary letter to the client, opting not to pursue any civil monetary penalties. The client was able to continue their operations without the burden of further sanctions or fines, thanks to the thorough and precise handling of their case.