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The Office of Foreign Assets Control (OFAC) is responsible for administering and enforcing U.S economic sanctions. policy. As part of this mission, OFAC maintains a list of Specially Designated Nationals (SDN). All U.S. persons are.
As aggravating factors, OFAC identified the number of alleged violations, the length of time involved, the companyâs lack of care in carrying on the activity for more than four years before realizing it was subject to U.S. jurisdiction, its lack of a compliance program during that period, and its level of commercial sophistication.