Tagged: North Korea sanctions

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...

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...

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...