August 20, 2021 - HHR provided counsel to a LatAm client throughout its successful two-year quest to unblock funds from a key account.

In 2019, HHR's client had $2.94 million frozen after an employee inadvertently attempted to use the account to remunerate a Cuban supplier.

The client submitted an internally drafted license application to unblock the funds with the U.S. Treasury Department's Office of Foreign Assets Control (OFAC), which administers and enforces economic and trade sanctions against foreign countries and regimes. Without the assistance of external specialized counsel, the company was unable to put forward a convincing argument to OFAC, which denied the application.

The client then enlisted the services of HHR to design and implement a risk-based, best-in-class sanctions compliance program following guidance from OFAC. The firm also conducted a full-scale investigation into the root causes of the incident and presented its findings – as well as remedial action taken to ensure such mistakes would not be repeated – and filed an application for reconsideration with OFAC.

On July 2021, OFAC granted the request for reconsideration and authorized the unblocking of the funds.

Diego Durán de la Vega and Ryan Fayhee led the HHR team, which also included Tyler Grove.