Tagged: OFAC sanctions

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...

Episode 206 — Update on Sanctions Compliance and Enforcement

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) continues to bring sanctions enforcement actions.  At the same time, OFAC is reiterating the importance of sanctions compliance program.  Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word — setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations. In this Episode, Michael Volkov...

United States and Global Community Adopt Broad Sanctions Targeting Belarus (Part III of IV)

The United States, the United Kingdom, the European Union, Canada and Switzerland have adopted or expanded sanctions against Belarus, and the Alexander Lukashenko regime.  President Biden issued a new executive order that expanded U.S. sanctions authority against Belarus, authorizing the designation of government officials, oligarchs and various companies linked to the Lukashenko regime.  The expanded sanctions authority now encompasses various sectors, including defense, energy, security,...

OFAC Screening and Internal Controls

Companies have had over one year to review and implement a sanctions compliance guidance program.  This last year, however, has been difficult (to say the least) given the COVID-19 pandemic.  Companies have had unusual challenges.  OFAC recognized the impact of COVID-19 when it issued guidance in April 2020 recognizing that companies faced challenging times and may have reallocated resources to meet pandemic needs. Prior to...

Episode 153 — Mighty Amazon Falls to the OFAC Sword

Amazon joins the exclusive club of high-tech OFAC violators.  Last year, Apple settled with OFAC for sanctions violations.  This year, we can add Amazon to the list of OFAC violators. On July 8, 2020, Amazon settled with OFAC for $134,523 for violations of multiple OFAC sanctions programs.  Amazon’s violations stemmed from deficiencies from its sanctions screening processes.  As a result, Amazon provided goods and services:...

Antitrust Compliance Lessons Learned from Chicken Price-Fixing investigation and Indictment (Part III of III)

The Antitrust Division’s recent indictment of the boiler chicken executives provided an important reminder to compliance officers on the importance of an effective antitrust compliance program.  With last year’s Guidance on Antitrust Compliance, DOJ has provided a roadmap for compliance officers to design and implement an effective compliance program.  Executive Level Participation and C-Suite Risk Assessment:  As described in the indictment, the price-fixing and bid-rigging...

Treasury, State Department and Coast Guard Issue Advisory and Guidance on Maritime Industry Deceptive Shipping Practices

In response to an increase in deceptive shipping practices, on May 14, 2020, the State Department, Treasury Department and the Coast Guard issued a warning to the maritime industry, and those involved in the energy and metals sectors, concerning deceptive shipping practices used to evade sanctions.  The focus of concerns appears to be actors seeking to circumvent  sanctions against Iran, North Korea and Syria. The...

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize.  The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks, and reflects the variety of ownership situations that occur. Given the overwhelming nature of the burden of a beneficial ownership risk mitigation strategy, we have to return to...

Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks.  Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes.  Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...

OFAC Releases Guidance on Sanctions Compliance During the Pandemic

Elizabeth Slim, Senior Consultant at The Volkov Law Group joins us for an important posting on OFAC sanctions compliance as a result of the pandemic.  Elizabeth can be reached at eslim@volkovlaw.com. It was only a matter of time before regulators and law enforcement recognized the impact that the pandemic has had on our country and our economy – The Office of Foreign Assets Control (“OFAC”)...