Tagged: OFAC Violations

British American Tobacco’s Financial Scheme to Avoid Sanctions Detection (Part II of II)

British American Tobacco’s deceit and elevation of business over compliance permeates its recent blockbuster settlement for $629 million with the Department of Justice and Office of Foreign Asset Control.  Importantly, the BAT settlement confirms DOJ’s new, aggressive approach to sanctions and export enforcement, and OFAC’s imposition of a penalty equal to the statutory maximum. For compliance professionals, the BAT scheme is interesting to review because...

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an approximately $7.8 million civil penalty for 9,256 violations of the Global Terrorism Sanctions Regulations (“GTSR”). SITA provides telecommunications services to companies in the civilian air transport industry.  Membership in SITA is open to industry operators worldwide...