OFAC is getting ready for a big year.  While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive enforcement of existing sanctions programs. The Justice Department and OFAC are forging a new enforcement partnership — and 2024 will be a precedent-setting year.  Stay tuned for more on this new...

How the Mighty Have Fallen – Old Testament (2 Samuel 1:19) The Harder They Come, the Harder they Fall – Jimmy Cliff (song) 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...

OFAC’s aggressive enforcement program continues to bear fruit.  The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program.  (Copy of Settlement Notice Here).  So far this year, OFAC has settled 22 cases for a total of approximately $1.28 billion (Statistics Here). Between 2010 and 2014, the GE companies accepted payment...

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018.  While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime, OFAC is beginning to clear some of the enforcement matters that have been pending. JP Morgan Chase agreed to a $5.2 million settlement with OFAC for 87 apparent violations from the processing of...

Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually played out in a variety of sanctions regimes and policies. This year, however, saw Congress enter the regulatory fray, when it imposed detailed regulatory requirements and procedures designed to constrain the current administration from making major changes...

With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered the sanctions landscape with the Iran Nuclear Treaty, and major changes in its relationship with Cuba and Myanmar (Burma). Since the major changes have been announced or implemented, there have been continuing...

I recently published an article on Trade Ready concerning export compliance and recent sanctions developments in Cuba and Iran.  A link to the article is here. Thanks for your continued support.