Tagged: ofac

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...

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks.  The latest settlement involved Whitford Worldwide Company (Whitford”), a cookware manufacturer based in Pennsylvania, which agreed to pay $824,314 for violations of the Iran Sanctions.  Whitford’s liability stemmed from...

Despite Pandemic, OFAC Settles with Animal Nutrition Company for $257k for Violations of Cuban Sanctions Program

OFAC announced a $257k settlement with Biomin America, Inc. (“Biomin”), an animal nutrition company based in Overland, Kansas, to settle violations of the Cuban Sanctions Program. OFAC recently issued guidance suggesting that organizations may re-allocate or reduce sanctions compliance operations based on the impact of the pandemic on an organization’s business activities.  Notwithstanding this guidance, OFAC announced this enforcement action, the first in several months,...

Videoconferencing and Export Controls

Janet Longo, Regulatory Compliance Analyst at The Volkov Law Group, joins us for a posting on videoconferencing and compliance export controls. Janet can be reached at jlongo@volkovlaw.com. As the Covid-19 virus is proliferating, so is the practice of conducting business through videoconferencing from home. While many commentators have discussed the serious data privacy and security problems associated with video conferencing, we’ve been thinking about the...

Webinar: How to Implement an Effective OFAC Sanctions Compliance Program

Webinar: How to Implement an Effective OFAC Sanctions Compliance Program 12 Noon EST, March 31, 2020 Sign Up HERE In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance programs. At the same time, OFAC has ramped up enforcement efforts. The Justice Department revised its...

Digging into High-Risk Distributors (Part II of II)

Compliance professionals are implementing their own monitoring and auditing strategies.  Internal audit does not have the resources nor the time to assume responsibility for this function.  If possible, internal audit may support, advise and assist in the monitoring and auditing functions.  Frankly, a partnership between compliance and internal audit in this area is ideal but compliance cannot wait for internal audit to join the mission. ...

Managing High-Risk Distributor Risks (Part I of II)

Companies will often rely on a network of distributors to help sell their products in emerging markets.  From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales force in a new market.  As a result, companies may enter a new market by relying on distributors, and if successful, may invest in the future by establishing its own...