Tagged: iran sanctions

Episode 294 — Catch Up on OFAC Enforcement Actions: 3M and Emigrant Bank

Episode 294 — Catch Up on OFAC Enforcement Actions: 3M and Emigrant Bank

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare institutions. Another federal agency, OFAC, yesterday announced that it had settled with 3M for $9.6 million over alleged violations of the Iranian Transactions and Sanctions Regulations. In another OFAC enforcement action, Emigrant Bank (“Emigrant”),...

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

Sam Finkelstein, an Associate at The Volkov Law Group, rejoins us for another posting about 3M’s recent settlement for violations of the Iran Sanctions Program. Sam can be reached at [email protected]. The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned...

OFAC Settles with Construction Specialties, Inc. for $660,594 for Violations of Iran Sanctions

OFAC Settles with Construction Specialties, Inc. for $660,594 for Violations of Iran Sanctions

Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct occurred through its United Arab Emirates (UAE) subsidiary, Construction Specialties Middle East (“CSME”), which imported building materials from the United States to the UAE and then knowingly reexported them to Iran. In...

Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities

Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on new guidance concerning Iranian unmanned aerial vehicles (“UAVs”). Alex can be reached at [email protected]. In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023,  aimed specifically at reminding industry of their obligations vis-a-vis...

Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k

Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k

Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million.  Murad was acquired by Unilever United States (“Unilever”) in 2015.  Once discovered, Unilever voluntarily disclosed the conduct to OFAC. The fallout from Murad’s long-running conspiracy: Unilever paid $3.3 million to OFAC for its Iran Sanctions violations.  Interestingly, OFAC...

OFAC’s New Year’s Eve Settlement with Danfoss for $4.3 Million for Sanctions Violations

OFAC’s New Year’s Eve Settlement with Danfoss for $4.3 Million for Sanctions Violations

OFAC closed out 2022 with a late-night $4.3 million settlement with Danfoss A/S, a Danish manufacturer of refrigeration and cooling products for violations of the Iran, Syria and Sudan sanctions programs.  OFAC has had a productive year – implementing and enforcing Russian sanctions while continuing its aggressive sanctions enforcement program.  For 2022, OFAC had 16 settlements along with $42 million in penalties.  Danfoss’ violations involved...

DOJ Ends Standoff & Agrees to DPA with Huawei CFO Wanzhou Meng

DOJ Ends Standoff & Agrees to DPA with Huawei CFO Wanzhou Meng

The long political and prosecution standoff between the U.S. Government/Department of Justice and Huawei/China ended abruptly last week when Wanzhou Meng, CFO of Huawei Technologies Co., Ltd. appeared in federal district court in Brooklyn and entered into a deferred prosecution agreement (DPA) and admitted to misleading global financial institutions. Meng was immediately released and returned to China. The resolution of Wanzhou Meng’s case resolved a...

First Bank of Romania Settles OFAC Violations for $862,318 (Part IV of IV)

First Bank of Romania Settles OFAC Violations for $862,318 (Part IV of IV)

The First Bank of Romania and JC Flowers agreed to pay OFAC $862,318 to settle violations of Iran and Syria Sanctions Programs.  First Bank is owned by its U.S. parent, JC Flowers & Company. In 2018, JC Flowers acquired a majority stake in First Bank, subjecting Frist Bank to OFAC sanctions. In early 2019, First Bank’s regulator, the National Bank of Romania flagged a U.S....

Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program

Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program

The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions.  As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is likely to increase.  Companies should expect more and complex sanctions, including anticipated strict sanctions against Russia for election interference.  OFAC’s mission and enforcement profile will increase.  At the same time, individual liability is...

UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program

UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program

UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions Program.  UniControl exported 19 shipments of its goods to two European countries with reason to know that the goods were intended for delivery to Iran end users.  In addition, UniControl exported two shipments...