Episode 63 — The Epsilon Case and Third-Party Sanctions Risks

The Department of Treasury’s Office of Foreign Asset Control (OFAC) recently settled a long-active enforcement action with Epsilon relating to alleged violations of the Iran Sanctions Program.  After a mixed decision from the US Court of Appeals for the District of Columbia Circuit, OFAC negotiated a $1.5 settlement for 39 violations of the Iran Sanctions Program.  Along the way, however, OFAC secured favorable rulings affirming application of its broad prohibition against third-party conduct where a company knows or has “reason to know” that a shipment intended to a third party may be shipped to a prohibited party.

In this episode, Michael Volkov discusses the Epsilon case and the implications for third party risks in sanctions cases.

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