Office of Compliance and Enforcement's Data Delivery Standards Guidance

Date issued: Feb. 26 2019

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TURBOFAC Commentary (106 words)

Notes:

1) The guidelines in this document are technically not mandatory, and OFAC does not specify when it would expect them to be complied with. Presumably, the size of a respondent company would and its resources, in addition to the complexity of a given investigation, would be significant factors informing OFAC's expectations in that regard. Whether a respondent is a company that OFAC would expect to have been involved in U.S.-based litigation entailing discovery could be another factor.

2) This document appears to have been superseded by OFAC Guidance: Production Submission Standards, though as of 7-5-24, this document remains live on OFAC's website.