OFAC has brought several significant enforcement actions in last two years that are described as the result of “screening errors.” These screening errors are sometimes described as the fault of sanctions screening software or human error. In this Episode, Michael Volkov reviews several OFAC enforcement cases stemming from screening errors, including Apple, Amazon, American Express and Cobham Metelics.
It is hard to argue that Apple and Amazon do not have the resources to implement state-of-the-art OFAC compliance programs. After all, the two largest companies in the world should stand as beacons of compliance with the full support of senior management, robust compliance departments, and sophisticated automated systems to support their compliance efforts. Apple Even the mighty can fall – Apple agreed to pay...
Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian company. SIS and its director and majority owner, Savo Stjepanovic, were designated under the Foreign Narcotics Kingpin Designation Act and added to the Specially Designated Nationals List (“SDN List”). Apple’s screening...
