Amazon joins the exclusive club of high-tech OFAC violators.  Last year, Apple settled with OFAC for sanctions violations.  This year, we can add Amazon to the list of OFAC violators.

On July 8, 2020, Amazon settled with OFAC for $134,523 for violations of multiple OFAC sanctions programs.  Amazon’s violations stemmed from deficiencies from its sanctions screening processes.  As a result, Amazon provided goods and services: (1) to persons sanctioned by OFAC located in Crimea, Iran and Syria; (2) to individuals located in or employed by the foreign missions of the countries sanctioned by OFAC.  In addition, Amazon failed to timely report several hundred transactions conducted pursuant to a general license issued by OFAC.

In this Episode, Michael Volkov reviews the sanctions enforcement matter for important issues, trends and lessons learned.