Category: General

Family International and Owner Pay $1.07 Million to Settle Violations of Russia Sanctions Program

Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with  OFAC for $1.07 million for 73 violations of the Russia Sanctions program.  In a separate criminal case, Roman Sinyavsky pleaded guilty to circumventing U.S. sanctions and money laundering.  Between 2018 and 2023, and 2023, Family International and Sinyavsky transferred nominal ownership of three luxury condominiums owned by two sanctioned Russian...

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control (“CNC”) machines, for dozens of violations of the Export Administration Regulations (“EAR”). The enforcement action stems from allegations that Haas facilitated the unauthorized export, reexport, or transfer of U.S.-origin machine...

Episode 354 — The New Era of Compliance: Generative AI, Data and Innovation

The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact? While its potential is undeniable, the road ahead is full of risks, challenges, and ethical concerns. Will AI drive efficiency and innovation, or will it create new vulnerabilities that companies must scramble to control? In...

Embracing Generative AI — The Current Risk Profile (Part II of II)

When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from employing AI capabilities in specific functions and use cases? Sometimes ethics and compliance professionals are surprised to learn that certain functions — finance, security, HR or others —...

The New Era of Compliance — AI, Data and Information Governance (Part I of II)

Not to sound like a broken record — but we are consistently asking the compliance community the same question. As far back as March 2013, on this very blog, I wrote a posting — The Future of Compliance — What Will the New Tools Look Like? To avoid being trite, but technology is moving so fast with blockchain, artificial intelligence and data analytics, we have...

FCPA Predictions: Don’t Expect Much to Change

In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and made his opinion known. The Trump Administration, however, did not dismantle FCPA enforcement and in fact, DOJ and the SEC increased FCPA enforcement.  DOJ and the...

Córdoba Music Group Settles with OFAC for $41,591 for Violations of Iran Sanctions Program

Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped instruments and related accessories that it knew were ultimately destined for Iran. Córdoba voluntarily self-disclosed the violations to OFAC.  Between June 4, 2014 and October 30, 2018, Córdoba maintained a distribution...

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations. In 2017, OFAC implemented regulatory sanctions derived from the Global Magnitsky Act and its associated Executive Order.  The 2017 Executive Order 13818 declared a national emergency with respect to serious human rights abuses...

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate enforcement program, akin to the FCPA, no new corporate cases were brought on the sanctions front.  2023 included the British American Tobacco as a bell whether of things to come. 2024 was interesting in...

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant prosecutions — but alas, they really did not materialize.  The modifications and tweaks to DOJ’s Corporate Enforcement Policy, however, were significant.  DOJ’s primary focus has been on accountability and prosecution of individuals...