Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for another post on an OFAC enforcement action. Sam can be reached at [email protected]. Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC announced that Emigrant agreed to...

Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for a new posting on OFAC’s announcement of new sanctions targeting Russia’s military-industrial complex.  Sam can be reached at [email protected]. The United States is determined to ensure that no one profits off of Russia’s war against Ukraine. To that end, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has widened the...

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. Click here to download the quarterly update for July. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...

OFAC continues its enforcement push.  At the same time, OFAC is managing a complex, global set of sanctions against Russia.  DOJ has promised to increase prosecution of global banks for sanctions violations. Meanwhile, OFAC reached another settlement with Swedbank Latvia AS (“Swedbank Latvia”), which is a subsidiary of “Swedbank AB”, a global bank headquartered in Stockholm, Sweden. Swedbank Latvia agreed to pay $3.43 million to...

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that.  Such a limited program provides just a  false comfort of compliance.  Many companies are not even conducting the mandated basic...

Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ, OFAC and the Bureau of Industry and Security have sent a loud message — $629 million from British American Tobacco and $300 million...

The Justice Department warned  companies that sanctions enforcement is the “new FCPA.” DOJ just delivered its first salvo to back up its message. As part of a broad effort to prosecute funding of North Korea’s nuclear program, DOJ and the Office of Foreign Assets Control (“OFAC”) announced a joint settlement with British American Tobacco and its Asian marketing subsidiary (“BAT”), under which BAT agreed to pay...