Comprehensive Response to OFAC Subpoena Resolves IT Company’s Sanctions Inquiry

Client Type and Situation:
A U.S.-based IT business received an administrative subpoena from OFAC, suspecting potential violations of sanctions regulations. Concerned about the implications and possible penalties, the client retained our firm to handle the matter and respond to OFAC’s inquiry.

Approach and Research:
We immediately negotiated with OFAC to secure an extension, allowing us ample time to gather and analyze the required documentation. Our legal team conducted an exhaustive review of the client’s transactions and scrutinized every detail related to the matters raised in the subpoena. This comprehensive research was essential for constructing a precise and complete response.

Steps Undertaken:
We drafted a thorough response to the subpoena, providing clear and detailed answers to each of OFAC’s questions. The supporting documentation was carefully assembled and organized in accordance with OFAC's standards. Throughout the process, we maintained open communication with the assigned OFAC officer, promptly addressing follow-up questions and submitting any additional evidence needed to clarify the situation.

Outcome:
After three months of review, OFAC opted to close the case without pursuing civil monetary penalties. Thanks to our strategic approach and diligent handling of the investigation, the client was able to resolve the matter efficiently, avoiding any further legal or financial consequences.