OFAC's administrative subpoenas — the '602 letters' — demand documents and explanations about specified transactions. They are compulsory, they are often broader than the underlying concern, and the response sets the trajectory of everything that follows.
Preservation first — the spoliation letter goes out internally the day the subpoena arrives. Privilege review before production, always: OFAC matters sit adjacent to potential criminal referrals, and what leaves the building never comes back. Where responses will reveal apparent violations, the self-disclosure calculus runs simultaneously — the subpoena hasn't necessarily destroyed voluntariness for conduct outside its four corners.
Enforcement actions test administrative subpoenas rarely and narrowly — relevance and burden negotiation with the office is the realistic lane, and it works more often than motion practice would.
The moment individual exposure diverges from corporate interest, yes — and spotting that moment early is part of the first-week job.
Silence, follow-ups, a prepenalty notice, or a closure letter — the response's completeness and the compliance story it tells influence which. The penalty-notice guide covers the worst branch.