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Alerts
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OFAC Publishes Economic Sanctions Enforcement Guidelines, Effective Nov. 9, 2009
February 12, 2010
On Nov. 9, 2009, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued the Economic Sanctions Enforcement Guidelines (“2009 Guidelines” or “the Guidelines”) as a final rule, effective Nov. 9, 2009. The 2009 Guidelines amend the interim final rule that OFAC previously published on Sept. 8, 2008 (“2008 Guidance”) with a request for comments. The Guidelines were amended, in part, as a result of public comments made in response to the 2008 Guidance. A summary of the 2008 Guidance, as well as additional background regarding OFAC, is set forth in our Alert dated Oct. 31, 2008, available on the Schulte Roth & Zabel website.
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