In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will review American Express and Cobham Metalics. American Express On April 30, 2020, OFAC issued a Finding of Violation (with no penalty) against American Express Travel Services for violations of  the...

Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian company.  SIS and its director and majority owner, Savo Stjepanovic, were designated under the Foreign Narcotics Kingpin Designation Act and added to the Specially Designated Nationals List (“SDN List”). Apple’s screening...