Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime.  OFAC has emphasized the importance of conducting supply chain risk assessments and audits.  A supply chain audit (akin to UFLPA and conflict minerals) is essential to assess, monitor and manage risks.  Even though parties are not in direct privity, a company that sources materials from a prohibited party or...

OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK.  This is not a simple matter.  In addition to this close coordinating responsibility, the United States and its allies are expanding  the reach and bite of the sanctions to restrict Russia and...

PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for cigarette paper exports to North Korea.  BMJ entered into an eighteen month deferred prosecution agreement with the Justice Department in exchange for the payment of the...