Tagged: ofac

Episode 218 — The Biden Administration’s New Strategy on Countering Corruption

The Biden Administration announced a new, comprehensive anti-corruption initiative, the United States Strategy on Countering Corruption. The new anti-corruption initiative is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern. After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The 38-page plan released last week outlines steps for cracking...

OFAC Implements New Ethiopia Sanctions Program

On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia, issued sanctions against four entities and two individuals as part of a new sanctions program in Ethiopia. OFAC issued the  sanctions is in response to humanitarian and human rights...

Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve

Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions Regulations.  The Sudan Sanctions Regulations were repealed on June 29, 2018. OFAC issued only a Finding of Violation, rather than impose a civil penalty, in light of Mashreqbank’s willingness to agree...

various cryptocurrency on table

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a post on sanctions compliance in the cryptocurrency industry. Matt can be contacted at MStankiewicz@volkovlaw.com. In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher course for sanctions compliance.  While the guidance was...

Trade Compliance Dominates Enforcement Landscape (Part I of IV)

Well, we are still waiting for the “big” FCPA enforcement actions.  Do not get me wrong – they are coming.  My suspicion is that they are being held up and calculated with a splash to announce the results of the White House’s Global Anti-Corruption Memorandum focusing on the anti-corruption effort as a national security priority.  The landscape is ready for a splash and DOJ is...

A Kinship with Sisyphus: Challenging an OFAC SDN Designation

There are lots of life lessons to apply from Greek Mythology. The classic character Sisyphus, who was punished by Zeus for his trickery and condemned for eternity to push a large boulder up a hill, reminds us of the consequences of punishment and the frustration from repetitive failure. How does this apply to trade sanctions compliance?  Bear with me here as I make the leap...

Episode 192 — The DOJ-SAP Settlement: A New Compliance Frontier

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program. While the Justice Department’s National Security Division (“NSD”) has settled prior export control and sanctions cases against corporations for violations of the North Korea Sanctions program, the SAP case is the first...

Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program

The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions.  As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is likely to increase.  Companies should expect more and complex sanctions, including anticipated strict sanctions against Russia for election interference.  OFAC’s mission and enforcement profile will increase.  At the same time, individual liability is...

Export Regulation 101—A Primer on U.S. Antiboycott Laws

Alex Cotoia, Regulatory Manager and Compliance Consultant at the Volkov Law Group, re-joins us for a posting on U.S. Antiboycott Laws. Alex can be reached at acotoia@volkovlaw.com. An often overlooked, but potentially substantial risk factor in a company’s export compliance strategy is the degree to which the company is both familiar with—and adheres to—U.S. Departments of Treasury and Commerce regulations governing the participation of covered...

The Urgency of Ethics and Compliance – The Biden Administration and Enforcement

The Biden Administration has a lot on its plate – that is obvious.  Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country.  Across the government, a new administration poses significant changes in priorities. The Justice Department will be tough on corporate crime and compliance.  With the exception of a failure to prosecute individuals responsible for...