Timothy O'Toole said that making sure foreign subsidiaries adhere to U.S. sanctions laws is one of the biggest challenges faced by global companies. In 2020, half of the enforcement actions announced by the Office of Foreign Assets Control (OFAC) related to a lack of understanding of how U.S. trade restrictions can be enforced outside the country or by executive misconduct at an overseas subsidiary. "This is for the most part because foreign subsidiaries often think of themselves as a local company and they talk to local competitors that have different rules, which creates a lot of misinformation on the ground," O'Toole said.