In Colombia, they call it “muerte civil,” civil death. In the United States, some lawyers prefer to call it purgatory, while others describe it as being closer to hell.
Getting blacklisted by the U.S. Treasury Department’s Office of Foreign Assets Control carries criminal and civil penalties, both for those who have been designated for sanctions and for any U.S. citizen or U.S. permanent resident who dares to do business with anyone or company that has been listed.
“You’re dealing with millions of dollars worth of fines (and) potential incarceration. It’s a very serious set of infractions,” said Adam M. Smith, a former Treasury official and current partner at Gibson, Dunn & Crutcher LLP in Washington, D.C. “The U.S. Attorney’s offices like in Southern District of Florida and Miami, main Justice in Washington, as well as agencies like the Treasury Department are going after people in very, very aggressive ways to find these violations. So there are serious risks.”
