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 [email protected]. 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”)...
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is aggressively enforcing OFAC sanctions rules. Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a “holistic” risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.
Bureau van Dijk, a Moodys Analytics Company, recently released a new white paper, What you need to know about sanctions compliance. You can download the white paper here. I was pleased to contribute to the white paper and hope you find it helpful.
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 [email protected], and Jessica can be contacted at [email protected]. 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...
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 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...
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...
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...
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...
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...
