Tagged: OFAC sanctions

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...

Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela

Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually played out in a variety of sanctions regimes and policies. This year, however, saw Congress enter the regulatory fray, when it imposed detailed regulatory requirements and procedures designed to constrain the current administration from making major changes...

Episode 12 — OFAC Screening and Sanctions Compliance

Global companies face ever-increasing risks with sanctions screening and compliance.  The US Treasury Department’s Office of Foreign Asset Control (“OFAC”) has aggressively enforced complex sanctions regulations against global companies, including banks, manufacturing, oil service and technology companies.  In this aggressive enforcement era, companies have to implement robust screening and compliance controls to identify sanctioned entities and individuals among their business partners and customers. In this...

The Strange Case of OFAC Against Exxon for Sanctions Violations

In a bizarre enforcement action, The Treasury Department’s Office of Foreign Asset Control (“OFAC”) assessed a $2 million civil monetary penalty against ExxonMobil (“Exxon”) for violations of the Ukraine sanctions. (Copy Here). OFAC’s enforcement action boiled down to Exxon’s execution of eight legal documents with Igor Sechin, the CEO of Rosneft OAO (“Rosneft”), who is a Specially Designated Nation and Blocked Person on what is...

TD Bank and Sanctions Violations

Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing. The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary disclosures when violations occur, and has set out an elaborate scheme regarding transparency. On the criminal...