Trustees and family office professionals occupy a privileged vantage point in global wealth management—a position that increasingly carries sanctions exposure.
A recent enforcement action by the Office of Foreign Assets Control against a former U.S. government official serving as a trustee underscores how seemingly routine fiduciary conduct can result in a sanctions violation. This rare action targeting an individual fiduciary highlights the importance of vigilance and caution when engaging in relationships involving high-risk countries and individuals.
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