Tagged: OFAC sanctions

Cryptocurrency Firm, Poloniex, Reaches Settlement with OFAC and Pays $7.5 Million for Sanctions Violations

The cryptocurrency industry has a target on its back – and perhaps justifiably so.  The SEC, CFTC and OFAC have been bringing a number of regulatory enforcement actions, including against Bittrex, Inc. ($24,280,829.20 in settlements with OFAC and FinCEN) and Payward, Inc. d/b/a Kraken ($362,158 settlement with OFAC).  Yet, the cryptocurrency has lots to worry about when it comes to compliance – fraud, cybersecurity, and...

OFAC Settles Two Cases with Credit Agricole Corporate Subsidiaries for $1.1 Million

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...

Newmont Corporation and Chisu International Settle with OFAC to Resolve Violations of Cuban Sanctions Program

Even while the Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been properly focused on implementing and enforcing the Russia sanctions scheme in response to Russia’s unprovoked invasion of Ukraine, OFAC had time to issue two enforcement actions involving violations of the Cuba Sanctions Program.  The two separate cases stem from four transactions involving Newmont Corporation, a global mining company, and Chisu International Corporation...

Episode 229 — DOJ Charges TV Producer with Violating Crimea-Related Sanctions

In another indication of DOJ’s aggressive approach to enforcement of sanctions against Russia, DOJ announced the indictment of a TV producer for violations of the Crimea-Related Russian sanctions program. As outlined in the indictment, Jack Hanick, a former Fox News executive, was indicted for a sanctions violations stemming from his long-time relationship with a prohibited Russian oligarch (Specially Designated National) relating to the creation and...

How to Avoid Sanctions Liability Following a Ransomware Attack

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...

Preparing for New Russia Sanctions Program: Are You Ready?

Jessica Sanderson, Partner at The Volkov Law Group, joins us for a blog posting on how to prepare for possible Russia sanctions in the event Russia invades the Ukraine. Jessica can be reached at [email protected]. Compliance Professionals: As the Ukraine braces for a possible Russian incursion, are you bracing for the impact of economic sanctions against Russia? In this article we offer suggestions to help...

Assessing Third-Party Sanctions Risks (Part II of III)

The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) sanctions regulations.  It is one thing to detect and prevent situations where a company actor has “actual knowledge” that a shipment to a third party is...

various cryptocurrency on table

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a post on sanctions compliance in the cryptocurrency industry. Matt can be contacted at [email protected]. In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher course for sanctions compliance.  While the guidance was...

The Elevation of Sanctions Compliance

This has been  an interesting enforcement year.  The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of political appointees has delayed the transition process.  Consequently, enforcement has gotten off to a slow start.  But companies would make a big mistake in embracing complacency or just waiting for enforcement to pick up before elevating...

NewTek, Inc., a Software Provider, Settles OFAC Violations for $189,483

The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets. NewTek, Inc. (“NewTek”), a software provider that develops and supplies live production and 3D animations hardware and software, agreed to pay $189,483 to settle 52 violations of the Iran Sanctions Program.  NewTek’s violations arose from its sales to foreign...