The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front.  That is not unusual — every transition results in an enforcement hiatus.  Sanctions enforcement is a priority for this Administration.  As expected, the Justice Department will play a more evident role in the sanctions enforcement process.  This a new development, when DOJ declines there may be disclosure of...

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of U.S. economic policy toward Syria. Acting in close coordination with the Department of State’s issuance of a national security waiver under Section 7425 of the Caesar Syria Civilian Protection Act of 2019...

With each new Administration comes a new approach or emphasis on certain enforcement priorities.  The Trump Administration is marking its territory and doing so to underscore its priorities.  In a recent speech, the Assistant Attorney General Matthew R. Galeotti for the Criminal Division announced DOJ’s new approach.  To reinforce this new approach, DOJ issued a new memorandum, Focus, Fairness and Efficiency in the Fight Against...

How do sanctioned Russian oligarchs continue to move their wealth despite international restrictions? The answer lies in real estate, shell companies, and complicit gatekeepers. In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into one of the latest OFAC enforcement actions against Family International and its owner, Roman Sinyavsky, for facilitating sanctions evasion on behalf of Russian oligarchs. Through complex real estate transactions,...

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant.  While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a Specially Designated National (“SDN”) under Executive Order 14024. This action,...

In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations of the Iranian Transactions and Sanctions Regulations (“ITSR”). The underlying violations, which occurred from 2019 to 2022, involved the purchase, renovation, and operation of a hotel on the Caspian...

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”)....

The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations.  The “New FCPA” is how the Justice Department characterizes its plan.  To execute the strategy, DOJ has assigned 25 new prosecutors.  This is the most important fact — unleashing 25 new prosecutors with the goal of bringing criminal cases against corporations and individuals will...

Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance.  OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure compliance with sanctions. OFAC’s concern was expressed in the context of its settlement with Murad LLC, a U.S. cosmetics company.  Over an eight-year period ending in 2018, Murad illegally exported goods and services...