Tagged: Iran Sanctions Program

Episode 72 — 2018 Review of OFAC Sanctions Enforcement and Compliance Trends

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) had a busy year — the first half of 2018 was dedicated to re-imposing the Iran Sanctions Program and updating the Russia Sanctions Program. In the second half of the year, OFAC resumed its pace for enforcement actions. In this episode, Michael Volkov reviews OFAC enforcement actions and sanctions regulations for 2018.

OFAC Completes Re-Imposition of Iran Sanctions

On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program.  The 180-day wind-down period for termination of the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) ended.  As part of the re-imposition of U.S. sanctions, OFAC added more than 700 individuals, entities, aircraft, and vessels to the SDN List,...

Episode 63 — The Epsilon Case and Third-Party Sanctions Risks

The Department of Treasury’s Office of Foreign Asset Control (OFAC) recently settled a long-active enforcement action with Epsilon relating to alleged violations of the Iran Sanctions Program.  After a mixed decision from the US Court of Appeals for the District of Columbia Circuit, OFAC negotiated a $1.5 settlement for 39 violations of the Iran Sanctions Program.  Along the way, however, OFAC secured favorable rulings affirming...

OFAC Enforcement: The Epsilon Case and Third Party Risks

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action.  (Here).  This case requires a theme song and there is none better than Truckin (here) from Grateful Dead’s second compilation album — What a Long Strange Trip its Been. This case involved two separate OFAC investigations for violations of the Iran Sanctions Program, an appeal to...