Tagged: OFAC sanctions

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

Matt Stankiewicz, Senior Associate, and Jessica Sanderson, Of Counsel, both at The Volkov Law Group, rejoin us for an interesting posting on a new OFAC reporting requirement. Matt can be contacted at mstankiewicz@volkovlaw.com, and Jessica can be contacted at jsanderson@volkovlaw.com. On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule...

Catching Up with OFAC Sanctions Enforcement Actions

OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities.  OFAC is aggressively seeking out new targets for enforcement.  OFAC continues to focus on Iran, Cuba, Venezuela and North Korea, aligning itself with current foreign policy objectives. Here is a brief outline of three recent enforcement actions: Western Union (HERE) — On June 7, 2019, OFAC released a settlement with Western Union under...

Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III)

Standard Chartered Bank certainly has its troubles.  You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the global French bank, which paid over $8 billion for pervasive US sanctions violations.  The Justice Department and OFAC have had a target-rich environment when reviewing global bank...

Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III)

Global banks are the poster children of sanctions violations and the importance of trade compliance.  At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the...

OFAC Announces Two Sanctions Enforcement Settlements

What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first enforcement action in June 2018. ELF Cosmetics  On January 31, 2019, OFAC announced a $996,080 settlement with e.l.f. Cosmetics, Inc. (“ELF”), a California cosmetics company for violation of the North...

Episode 62 — Update on the Cuba and Venezuela OFAC Sanctions Programs

The Trump Administration has aggressively restricted commerce with Cuba and Venezuela.  With respect to Cuba, the Trump Administration has re-imposed strict regulations on commerce with Cuba, reversing several Obama-era regulations easing such restrictions.  At the same time, the Trump Administration has continued Obama era policies tightening trade with Venezuela and opposing the Maduro leadership in Venezuela. In this episode, Michael Volkov discusses recent updates to...

Hallelujah: OFAC Announces First Enforcement Action in 2018 Against Ericsson, Inc.

I will admit it – I changed this posting from its original draft.  I intended to write about the absence of any OFAC enforcement actions for 2018.  I went to double-check the OFAC enforcement website (here), and lo and behold, OFAC snuck its first enforcement action of 2018 – dated June 6, 2018 against Ericsson, Inc. for $145,983. Before the Ericsson enforcement action, OFAC had...

Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program

Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program June 12, 2018 12 Noon EST Sign Up Here Sanctions compliance has become more complex and difficult. The Russia-Ukraine Sanctions Program includes detailed sectoral sanctions and comprehensive “oligarch” sanctions against Russia’s leading industrial oligarchs. Compliance officers have to ensure that their trade compliance programs are nimble and able to adapt to the ever-changing compliance environment. Join...

Update on Russia Trade Sanctions

The Trump Administration Treasury Department’s Office of Foreign Asset Control activity has been interesting to watch.  On the one hand, OFAC has been implementing aggressive sanctions against Russia in reaction to Russia’s global misconduct.  On the other hand, OFAC has brought  — no, none, zip — enforcement actions this year.  That is unprecedented and inexplicable. I doubt that all staff has been dedicated to drafting...

OFAC Hits Russia with New Sanctions

On April 6, 2018, OFAC announced a new round of sanctions against Russian individuals and companies.  (For Press Release Here; new FAQs Here; and new General Licenses 12 Here and 13 Here).  Relying on its authority under existing executive orders, OFAC designated seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials and a state-owned weapons trading company, and its...