“Sanctions for Sanctions Violation”: U.S. Department of Treasury Enforcement Actions Against the Financial Sector

... “enforcement actions” concept; these actions target both Americans and foreigners. Although there is no generally accepted “secondary sanctions” concept, it appears expedient to use it in this particular meaning without reducing it solely to extra-territorial ... ... literature. Study Design The imposition of sanctions by the U.S. Department of the Treasury and its Office of Foreign Assets Control (OFAC) is extensively regulated by 2009 guidelines that set several important parameters. First, the amount of the fine depends ...