How to respond to an OFAC inquiry or subpoena

OFAC inquiry response: (1) Acknowledge receipt promptly. (2) Consult sanctions counsel before responding substantively. (3) Gather requested documents — screening logs, policies, transaction records. (4) Respond within the stated deadline. (5) Be truthful — false statements to OFAC are a separate offense. (6) Cooperate — cooperation is a mitigating factor.