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...

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. Click here to download the quarterly update for April. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...

OFAC is getting ready for a big year.  While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive enforcement of existing sanctions programs. The Justice Department and OFAC are forging a new enforcement partnership — and 2024 will be a precedent-setting year.  Stay tuned for more on this new...

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few years.  The reasons for that are unclear — is it resources, difficulty and length of investigations or just lack of initiative?  Whatever the cause may be, one...

The Office of Foreign Assets Control (“OFAC”) has demonstrated its ability to multi-task — designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining its “regular” enforcement program. In a recent two-fisted settlement, OFAC reached two separate settlements with Credit Agricole companies.  First, OFAC reached a settlement with Credit Indosuez Switzerland S.A. (“CAIS”), an indirect subsidiary of Swiss-based...

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for an interesting post on ransomware and OFAC sanctions compliance. Matt can be reached at [email protected]. Ransomware attacks are on the rise and companies everywhere should be taking action to strengthen their cybersecurity defenses and resiliency to ensure their internal systems are able to withstand cybercrime attacks.  Cybercriminals are exceedingly sophisticated, some groups even maintain...