Thorough Response Prevents Sanctions Penalties for Software Development Firm

Client Type and Situation:
A U.S.-based software development company received an administrative subpoena from OFAC, which raised concerns over potential sanctions violations. Faced with the complexity of the situation, the client sought our firm’s expertise to manage the process and respond to OFAC’s inquiries.

Approach and Research:
We successfully negotiated a time extension with OFAC, allowing the client to gather the necessary documentation. Our legal team conducted a comprehensive review of the transactions flagged in the subpoena, carefully analyzing all relevant data. This meticulous research enabled us to fully understand the issues at hand and craft an accurate response.

Steps Undertaken:
We drafted a detailed and well-supported response to the subpoena, addressing every question raised by OFAC. The response included all requested supporting documents, and we ensured that the narrative and evidence were organized in full compliance with OFAC’s standards. Additionally, we maintained regular communication with the assigned OFAC officer, responding to any further inquiries and providing additional evidence as needed.

Outcome:
After approximately 3.5 months, OFAC closed the case without pursuing any civil monetary penalties. Through our diligent preparation, clear communication, and thorough documentation, we were able to help the client resolve the matter effectively, avoiding further legal or financial consequences.