Tagged: ofac

Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations

The Department of Justice is pushing its commitment to voluntary disclosure programs.  Companies, however, are not lining up at DOJ’s door.  The balance between sitting tight or voluntary disclosures requires care. To complicate matters further, in certain cases, regulated companies have to face civil enforcement issues and coordinate voluntary disclosure programs offered by regulatory agencies.   A perfect example of this dual track situation is compliance...

OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus voluntarily disclosed three unauthorized transactions in which a Specially Designated National (“SDN”) had an interest. Nodus failed to maintain accurate records related to the handling of blocked property.  OFAC determined that a FoV...

Lessons Learned from OFAC’s Settlement with Tango Card

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a review of OFAC’s recent settlement with Tango Card for sanctions violations. Alex can be reached at [email protected] On September 30, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) announced a settlement with Tango Card, Inc. (“Tango Card”), a supplier and distributor of stored valued cards used...

Banco Popular de Puerto Rico Settles with OFAC for $255,937 for Violations of Venezuela Sanctions Program

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is a busy enforcement agency.  OFAC has implemented the comprehensive Russia Sanctions Program in response to Russia’s invasion of the Ukraine.  The scope and pace of this process has been unprecedented.  Along the way, OFAC is continuing a steady pace of sanctions enforcement actions.  In a recent action, Banco Popular de Puerto Rico (“Banco Popular”), a...

United States and EU Expand Russian Sanctions and Export Controls

In its continuing ratcheting of sanctions against Russia, the United States and the European Union have announced new sanctions and export controls to target additional industries and government officials.  In a new front, the US and EU included a ban on accounting and business consulting services.  The new US restrictions extend to broad export controls and sanctions focused on Russian banking executives, a weapons manufacturer...

Sanctions Enforcement: “The New FCPA”

Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go.  Deputy Attorney General Lisa Monaco was recently quoted stating that sanctions enforcement is the “new FCPA.” This is not so surprising given the global crisis caused...

OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions Program

Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program.  The message being sent is clear – do not violate any sanctions against Russia, whether the initial round of restrictions in 2014 in response to Russia’s annexation of Crimea, or the broader sanctions recently implemented in response to Russia’s broader invasion of...

Episode 228 — Update on Russia Sanctions and Export Controls

The continuing crisis in Ukraine has resulted in additional sanctions and export controls. It is hard to keep up with new developments each day. In recent steps, the United States has adopted a comprehensive set of export controls and implemented a ban on import of Russian oil, gas and coal. In this Episode, Michael Volkov reviews the recent changes to the Russia sanctions and export...

United States Announces Initial Sanctions in Response to Russia’s Invasion of Two Ukraine Regions

In response to Russia’s invasion of Ukraine territories, the so-called Donetsk and Luhansk People’s Republics, respectively, (hereinafter “DNR” and “LNR”), yesterday, on February 21, 2022, President Biden issued a new Executive Order targeting the DNR and LNR regions of Ukraine with comprehensive sanctions.[1] In practical effect, the new sanctions impose an embargo similar to that imposed against the Region of Crimea after Russia annexed the...

Managing Third-Party Sanctions Risks (Part I of III)

If there is one issue that is repeated over and over (and over), it is third-party risks.  Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world.  And with this enforcement focus, it was inevitable that third-party risk would become one of the core areas for ethics and compliance programs. Indeed, the importance of third-party risk is underscored by...