Rethinking Sanctions Efficiency

... in some cases other regulators take part in coercive actions. The Department of Justice, the Department of Commerce, the Federal Reserve System Board of Governors and other institutions may participate in investigations vis a vis American and foreign businesses. However, OFAC usually plays the leading role in relations with business. Generally, OFAC implements two basic options to punish a violator. The first one is to include it in the SDN list which prohibits U.S. persons and entities under U.S. jurisdiction from dealing ...