Tagged: ofac

Episode 319 — Deep Dive into SCG Plastics $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no further than OFAC’s recent settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the Iran...

DOJ Charges Ten Individuals for Violating Venezuelan Sanctions

On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the individuals conspired to decade U.S. sanctions imposed on Petroleos de Venezuela S.A. (“PDVSA”) in January 2019. In April 2024, one of the defendants was arrested upon arrival at Miami’s internal Airport.  The Violations...

briqven factory in ciudad guayana in venezuela

La Oficina de Control de Activos (OFAC) no renovó la licencia 44 y en consecuencia se revoca el alivio de Sanciones a Venezuela

El 17 de abril de 2024, la OFAC revocó formalmente el alivio de sanciones que anteriormente había proporcionado a la industria petrolera y de gas en Venezuela. Mediante la licencia 44 la OFAC había proporcionado un alivio de sanciones a Venezuela en condición de que el gobierno de Venezuela organizara unas elecciones libres y justas. Debido al incumplimiento del gobierno de Venezuela, la OFAC revocó...

briqven factory in ciudad guayana in venezuela

OFAC Rolls Back Venezuelan Sanctions Relief, Again Prohibiting Oil and Gas Transactions

On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry.  While OFAC provided the initial relief believing that Venezuela would permit a fair and open election, it appears that the Maduro regime has fallen short of its commitments.  As such, and as part of its agreement with the beleaguered South American nation, OFAC has...

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...

Episode 313 — The Coming Sanctions Criminal Corporate Enforcement Storm

There are some things you learn best in calm, and some in storm.  Will Cather DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ’s enforcement initiative is coming — it is just a question as to when. In this Episode, Michael Volkov reviews the elements...

Biden Administration Responds to Death of Alexey Navalny with Additional Sanctions Against Russia Federation

Following the death of opposition politician Alexey Navalny, the Biden Administration announced a large swath of new and additional sanctions on the Russian Federation.  The U.S. Department of Treasury’s Office of Foreign Assets Control (”OFAC”), in conjunction with the Department of State and the Department of Commerce, added almost 300 individuals and entities to the Specially Designated Nationals List (“SDN List”).  Later in the day,...

2023 Sanctions Year in Review and Predictions

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up...

OFAC Bolsters Russian Oil Price Cap Record-Keeping Requirements in New Round of Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements for maritime shipping operators and other industries that participate in the transport of Russian oil. OFAC also announced sanctions against several firms operating in apparent violation of the Price Cap. The Price Cap Policy is...

Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure

When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. So was the case for Nasdaq, Inc., which this week settled Iran sanctions violations in what could have been a $458 million OFAC penalty, for just $4.04 million, less than 1% of the applicable statutory maximum.  For those who view compliance...