DOJ Sanctions Enforcement Archives - Corruption, Crime & Compliance

3 May, 2023

British American Tobacco’s Financial Scheme to Avoid Sanctions Detection (Part II of II)

British American Tobacco’s deceit and elevation of business over compliance permeates its recent blockbuster settlement for $629 million with the Department of Justice and Office of Foreign Asset Control. Importantly, the BAT settlement confirms DOJ’s new, aggressive approach to sanctions and export enforcement, and OFAC’s imposition of a penalty equal to the statutory maximum. For compliance professionals, the BAT scheme is interesting to review because...

General

13 Jan, 2022

2022 OFAC and Sanctions Enforcement Predictions

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment. Since the pandemic, OFAC has maintained a strong profile, while managing a difficult portfolio of economic sanctions. The last two administrations have relied on robust sanctions programs to leverage foreign policy interests. With the ongoing tension between the US and China and Russia, OFAC is going...

General

4 May, 2021

SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)

When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern. A company starts with inadequate compliance controls, engages in violations driven by the desire to earn money and increase business, learns about the violations through an internal audit, compliance program assessment and/or whistleblower...

General

18 Feb, 2021

DOJ and OFAC Settle with Indonesian Company for $2.5 Million for Violations of the North Korea Sanctions Program

PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for cigarette paper exports to North Korea. BMJ entered into an eighteen month deferred prosecution agreement with the Justice Department in exchange for the payment of the...

General

27 Jul, 2020

DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions

The Justice Department and OFAC announced a settlement with Essentra FZE Company Limited (“Essentra FZE”), a cigarette filter and tear tape manufacturer, for violation of the North Korea Sanctions Program. The violations were based on payments for goods that were received by a foreign branch of a U.S. bank. Essentra FZE, a UAE company, manufactures and sells cigarette filters and tear tape for customers in...