Tagged: OFAC enforcement

Episode 98 — Quick Dive into Recent OFAC Enforcement Actions

So far in 2019, OFAC is sending a strong message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement, emphasizing compliance with Cuba and Iran sanctions programs, and focusing on US companies that acquire foreign subsidiaries to ensure post-closing compliance with OFAC sanctions regulations. In this episode Michael Volkov discusses recent trends in OFAC enforcement actions and priorities.

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

Jessica Sanderson, Of Counsel at the Volkov Law Group, rejoins us for a posting on OFAC’s recent enforcement actions involving Expedia and other cases involving acquisitions of foreign-owned companies. Jessica can be reached at jsanderson@volkovlaw.com. On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200...

The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation

Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex.  The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more.  In order to enforce these laws and regulations, OFAC must necessarily...

Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned

OFAC is off to a fast start in 2019.  It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.

OFAC Enforcement: The Epsilon Case and Third Party Risks

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action.  (Here).  This case requires a theme song and there is none better than Truckin (here) from Grateful Dead’s second compilation album — What a Long Strange Trip its Been. This case involved two separate OFAC investigations for violations of the Iran Sanctions Program, an appeal to...

OFAC Pushes Iran Sanctions Enforcement

Many companies have been laser-focused on anti-corruption compliance, and with good reason given the risks and consequences of an anti-corruption enforcement action. In doing so, companies have to be careful to avoid ignoring sanctions risks, especially in the ever-evolving nature of sanctions rules and regulations. The Office of Foreign Asset Control is an enforcement agency that coordinates its investigations activity with the Department of Justice...