North Korea sanctions Archives - Corruption, Crime & Compliance

2 May, 2023

British American Tobacco Pays $629 Million to Settle Violations of North Korea Sanctions (Part I of II)

The Justice Department warned companies that sanctions enforcement is the “new FCPA.” DOJ just delivered its first salvo to back up its message. As part of a broad effort to prosecute funding of North Korea’s nuclear program, DOJ and the Office of Foreign Assets Control (“OFAC”) announced a joint settlement with British American Tobacco and its Asian marketing subsidiary (“BAT”), under which BAT agreed to pay...

General

15 Mar, 2023

OFAC Settles First Case in 2023: Godfrey Phillips India Pays $332,500 for Violations of North Korea Sanctions Program

OFAC had a quiet start to the year – no enforcement actions but plenty of new and revised sanctions against Russia. OFAC started off March 2023 with a new enforcement action against Godfrey Phillips India, a tobacco manufacturer headquartered in India. Godfrey Phillips India (“GPI”) agreed to pay $332,500 for five violations of the North Korea Sanctions Program. GPI’s violations stemmed indirectly from GPI’s receipt...

General

6 Mar, 2022

DOJ Enforcement and Compliance with the New Russian Sanctions

The Department of Justice has announced its plan to aggressively enforce the new Russia Sanctions Program. In response to the dire humanitarian situation in the Ukraine, DOJ took two significant actions – creation of the KleptoCapture Task Force and a commitment to enforcement of the Russia sanctions and export control. DOJ’s second statement of intent is significant. DOJ’s record of criminal enforcement of prior sanctions...

General

10 Jan, 2022

OFAC Closes Out Year with Two-Fisted Settlement with TD Bank

The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program. At the end of the year, OFAC announced a settlement with TD Bank for $115,000 for two separate sanctions violations. In the first, TD Bank illegally processed nearly 1,500 transactions that violated US sanctions against North Korea. Interestingly, it does not...

Uncategorized

7 Aug, 2017

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...