Tagged: OFAC Ukraine-Russia Sanctions

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for 38 apparent violations of the Ukraine/Russia-Related Sanctions Regulations, which occurred between December 2016 and May 2020. State Street is a global financial services and bank holding company headquartered in Boston, and is...

Cameron Settles OFAC Case for $1.4 Million for Violation of Ukraine-Russia Sanctions (Part I of II)

In a pair of enforcement actions, here and here, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. Cameron agreed to pay $1.423 million to settle OFAC charges for providing services to the Gazprom-Neft Shelf for an Arctic offshore oil...

Sanctions Enforcement and Compliance Year in Review

The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape.  Global companies now face a complex regime of sanctions that require careful navigation. As the U.S. government expands its reliance on sanctions to influence foreign actors and advance foreign policy interests, global companies have to design and implement robust trade compliance programs.  In recognition of this...

OFAC Announces Russia Sanctions Settlement with Software Company

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for violations of OFAC’s Ukraine-Russia sanctions program.  (OFAC announcement here). Metelics violated the Ukraine-Russia sanctions program on three occasions between July 31, 2014 and January 15, 2015,  by selling telecommunications and computer software (3,400 switch limiters;...