Tagged: OFAC Sanctions enforcement

4 May, 2021

SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)

When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern. A company starts with inadequate compliance controls, engages in violations driven by the desire to earn money and increase business, learns about the violations through an internal audit, compliance program assessment and/or whistleblower...

General

7 Jan, 2021

OFAC Ends 2020 with Two Enforcement Actions

OFAC reported two new enforcement actions in the week between Christmas and New Year’s. The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital currency company. BitGo Settlement BitGo, Inc. a technology platform that provides digital asset wallet management, agreed to pay $98,830 to settle 183 apparent violations of multiple sanctions programs, including the Crimea...

Podcasts

11 Oct, 2020

Episode 164 — Catching Up on Recent OFAC Enforcement Actions

OFAC has resumed its aggressive enforcement program. These enforcement actions include: (1) Keysight Technologies settled with OFAC for $473,157 for violations of the Iran Sanctions Program; (2) Comtech Telecommunications settled with OFAC for $894,111 for violations of Sudan Sanctions Program; and (3) Deutsche Bank settles two OFAC cases totaling $583K for violations of Ukraine-Russia Sanctions Program. In this Episode, Michael Volkov discusses these three separate enforcement actions. The...

General

27 Jul, 2020

DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions

The Justice Department and OFAC announced a settlement with Essentra FZE Company Limited (“Essentra FZE”), a cigarette filter and tear tape manufacturer, for violation of the North Korea Sanctions Program. The violations were based on payments for goods that were received by a foreign branch of a U.S. bank. Essentra FZE, a UAE company, manufactures and sells cigarette filters and tear tape for customers in...

Events

18 Jul, 2020

Webinar: 2020 Mid-Year OFAC Sanctions and Compliance Review

2020 Mid-Year OFAC Sanctions Compliance Review August 4, 2020, 12 Noon EST Sign Up Here Despite the pandemic and disruptions to the global economy, the Office of Foreign Asset Control continues its aggressive enforcement of economic sanctions. OFAC has brought several significant enforcement actions, and the Justice Department joined in one enforcement action for violation of the North Korea sanctions programs. While OFAC has recognized...

General

20 Jan, 2020

2019 OFAC Sanctions Enforcement Review (Part I of II)

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase over 2018 when OFAC collected $71 million in 7 separate enforcement actions. OFAC enforcement is maturing, and its relationship with DOJ is coordinated in much the same way that...

Podcasts

19 Jan, 2020

Episode 123 — 2019 OFAC Enforcement and Compliance Review

2019 was a big year for OFAC enforcement and compliance — OFAC collected $1.28 billion in fines and penalties in a total of 26 separate enforcement actions. OFAC also issued important compliance program guidance, mandating a number of important requirements for compliance programs. OFAC’s enforcement record for 2019 focused on supply chain sourcing; acquisition of foreign companies engaged in transactions with prohibited countries and customers;...

General

12 Jun, 2019

OFAC Fines US Company for Iran Sanctions Violations

There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors. OFAC has exercised its prosecutorial discretion to underscore the risks global companies face in their distribution channel, i.e. use of third party distributors, and in its supply chain. These twin risk areas...

General

28 Mar, 2019

Stanley Black and Decker Settles OFAC Enforcement Action for $1.9 Million

Stanley Black and Decker (“Stanley”) and its Chinese subsidiary Jiangsu Guoqiang Tools Co. (“GQ”) agreed to pay approximately $1.9 million to settle OFAC charges that it violated the Iran Sanctions Program. The OFAC enforcement action was the fifth in 2019. Stanley voluntarily disclosed the apparent violations to OFAC. See Here for a copy of OFAC Enforcement Action. Between June 2013 and December 2014, GQ exported...

General

7 Jan, 2019

Sanctions Enforcement and Compliance Year in Review

The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape. Global companies now face a complex regime of sanctions that require careful navigation. As the U.S. government expands its reliance on sanctions to influence foreign actors and advance foreign policy interests, global companies have to design and implement robust trade compliance programs. In recognition of this...