Please let me know if your institution has considered the question of personal OFAC liability when U.S. citizens are sent to work in foreign country, e.g., Canada, France, Japan, and the foreign bank transacts business or facilitates transactions with countries embargoed by the U.S., but not the foreign country. What if the U.S. citizen is a manager with no direct involvement in the transactions, but with putative supervisory authority over the operations engaging in the transaction. Any experience with or comments concerning this situation?

Have you thought about contacting OFAC directly and asking them your scenerio? If you do, and receive an informative answer that you can share, please share it with us.

Opinions are mine not my employer.