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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.
OFAC considered the following to be aggravating factors: Decolar had demonstrated reckless disregard for U.S. sanctions requirements by unreasonably relying on a third partyâs oral assurances (not specified in the Web posting) that the travel services did not require an OFAC license; Decolarâs senior management was aware of the activity; Decolarâs was commercially sophisticated; Decolar lacked an adequate OFAC compliance program; and the activity caused âsignificant harm to US ...