Tagged: iran sanctions

The Mighty Amazon Falls to the OFAC Sanctions Sword

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 Announces $1.7 Million Settlement with Truck Manufacturer for Violations of Iran Sanctions Program

In yet another enforcement action, OFAC announced a $1.709 million settlement with PACCAR, Inc., for 63 apparent violations of the Iran Sanctions Program by DAF Trucks, a wholly-owned subsidiary based in Eindhoven, Netherlands.  (Here). On three separate occasions, between October 2013 and February 2015, DAF sold or supplied 63 trucks to customers in Europe that it knew or had reason to know were ultimately intended...

OFAC Announces Two Sanctions Enforcement Settlements

What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first enforcement action in June 2018. ELF Cosmetics  On January 31, 2019, OFAC announced a $996,080 settlement with e.l.f. Cosmetics, Inc. (“ELF”), a California cosmetics company for violation of the North...

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,...

JP Morgan Chase Bank Settles “Old” Sanctions Case for $5 Million

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...

OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions

The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”).  In doing so, the executive order consolidates relevant sanctions authorities and broadens the scope of the previous restrictions. Companies will now have to comply with a renewed set of secondary sanctions, and...

Iran Sanctions and Third Party Risk

United States businesses are experiencing a sanctions whipsaw.  Since 1979, the President has issued twenty-six Executive Orders restricting trade and commerce with Iran. The Iran Sanctions Program imposed strict prohibitions in a range of areas.  The Iran Sanctions Program and the Cuba Embargo are the two most restrict sanctions program implemented by the United States. All of this changed in January 2016 when the Joint...

Turning Back the Clock – OFAC Plans to Reimpose Iran Sanctions Program

History does not repeat itself but it often rhymes — Mark Twain (although there is disagreement if Twain uttered these exact words (see here)). Just as businesses were growing or planning to grow into Iran, they had the proverbial rug pulled out from under them. Last week, on May 8, 2018, the administration announced its intention to withdraw from the Joint Comprehensive Plan of Action...

New Sanctions Law Complicates Trade Compliance

Politics and sanctions law go hand-in-hand. In a rare instance of bi-partisanship, Congress united to constrain the administration’s ability to modify the existing sanctions program against Russia. At the same time, Congress expanded the sanctions regime for Russia, Iran and North Korea. The administration was forced to sign the bill given the overwhelming vote in favor of the measure. As a result, compliance practitioners have...

TD Bank and Sanctions Violations

Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing. The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary disclosures when violations occur, and has set out an elaborate scheme regarding transparency. On the criminal...