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...

In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. In this Episode, MIchael Volkov reviews the two OFAC enforcement actions.

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...

In the new Biden Administration, companies should expect aggressive enforcement of trade sanctions.  At the same time, in response to Russian aggression and the Solar Winds cyber-attack, OFAC is likely to implement new and even more restrictive sanctions against Russia.  In anticipation, companies should elevate the importance of their sanctions compliance programs (SCPs) pursuant to the May 2019 OFAC Framework.  Unfortunately, for many companies, sanctions...

OFAC continues to chalk up enforcement actions.  For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties. In its latest enforcement settlement, Generali Global Assistance, Inc. (“GGA”), a US-based travel assistance services company that provides travel and claims services on behalf of clients that offer global medical expense and travel insurance policies, agreed to pay...

I often remind readers – government prosecutors regularly tell you what they  plan to do in advance, and then they do it.  So do not be surprised when the government does something they told you they would do. In May 2019, OFAC issued its Framework for Sanctions Compliance Commitments.  As part of its Guidance. OFAC noted that it intended to increase enforcement actions against individual...

OFAC’s aggressive enforcement program continues.  Recently, OFAC announced settlements with Apollo Aviation and Apple.  Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode, Michael Volkov reviews the two cases and the specific lessons learned.