Recent OFAC and DOJ actions have focused on certain entities—overseas financial institutions—and particular conduct—US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated criminal plea with Schlumberger Oilfield Holdings Ltd., however, reflects a break from this trend. Relying on a theory of “facilitation” and wielding aggressive criminal charges, the DOJ dramatically expanded the scope of prior criminal enforcement actions in the OFAC arena. The DOJ’s latest stance also signaled to US manufacturing companies: there is more to come.View full memo, “Facilitation”: A New Tool for Extraterritorial Sanctions Enforcement?
