Tagged: OFAC enforcement

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...

Episode 209 — Schlumberger Settles Two OFAC Enforcement Actions

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 Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program

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...

OFAC Starts New Year with Enforcement Action against French Bank for Violations of Syrian Sanctions Program

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...

Five Basic Steps to Implement a Sanctions Compliance Program

Companies have to implement a sanctions compliance program (SCP).  When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent.  Too many companies are behind the 8-ball when it comes to sanctions compliance. The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes...

OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban 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...

OFAC Settles Enforcement Action with Individual for $5000

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 Issues First Two Enforcement Actions of 2020

OFAC had a big year in 2019 and 2020 looks like a continuation.  In the last week, OFAC issued two enforcement actions —  Eagle Shipping (here) and Park Strategies (here). Eagle Shipping Eagle Shipping, a Marshall Islands company, headquartered in Stamford, Connecticut, agreed to pay OFAC $1.125 million to settle liability for 36 violations of the Burmese Sanctions program.  Specifically Eagle Shipping dealt with Myawaddy...

Episode 118 — OFAC Enforcement Update and Lessons Learned

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.

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.