In the new Biden Administration, companies should expect aggressive enforcement of trade sanctions.  At the same time, in response to Russian aggression and the Solar Winds cyber-attack, OFAC is likely to implement new and even more restrictive sanctions against Russia.  In anticipation, companies should elevate the importance of their sanctions compliance programs (SCPs) pursuant to the May 2019 OFAC Framework.  Unfortunately, for many companies, sanctions compliance does not get the attention it deserves. Those companies that ignore sanctions risks are operating in peril.

In this Episode, Michael Volkov reviews the 2021 OFAC enforcement actions of the year involving five separate cases, including (1) Union de Banques Arabes et Françaises; (2) PT Bukit Muria Jaya; (3) BitPay, Inc.; (4) UniControl, Inc.; and (5) Nordgas, S.r.l.