Litigation partners Roberto Gonzalez and Nicole Succar and counsel Sam Kleiner wrote an article discussing two recent enforcement actions by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) involving investment firms, including a private equity firm and a venture capital firm. In the article, “2 OFAC Sanctions Actions Highlight PE Compliance Risk,” published on January 15, the authors note that OFAC’s actions underscore the obligation of private equity and other investment firms to implement risk-based sanctions compliance programs, particularly in situations involving complex or opaque legal structures.
“[T]hese OFAC enforcement actions underscore that sanctions obligations apply to all types of financial institutions, including private equity firms and hedge funds. Such firms may wish to consider reviewing their sanctions compliance programs to ensure that they have effective and risk-based controls for identifying indirect exposure to sanctioned persons.”
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