Tagged: ofac

22 May, 2023

Episode 275 — Five Steps to Enhance Your Sanctions Compliance Program

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, 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 requirement of annual...

General

18 May, 2023

Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III)

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...

General

17 May, 2023

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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...

General

2 May, 2023

British American Tobacco Pays $629 Million to Settle Violations of North Korea Sanctions (Part I of II)

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...

Events

1 May, 2023

Webinar: “The New FCPA”: Sanctions and Export Control Enforcement

Webinar: “The New FCPA”: Sanctions and Export Control Enforcement Tuesday, June 6, 2023, 12 Noon EST Sign Up HERE Last year, the Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted “The New FCPA.” DOJ, the Treasury Department’s Office of Foreign Asset Control...

Podcasts

24 Apr, 2023

Episode 271 — A Deep Dive into the Microsoft OFAC Settlement

Microsoft agreed to pay $2,980,265.86 for illegal exports of services and software to sanctioned jurisdictions and Specially Designated Nationals (“SDNs”) in violation of OFAC’s Cuba, Iran, Syria, and Ukraine-/Russia-Related sanctions programs. Most of the violations involved prohibited Russian entities or persons located in the Crimea region of Ukraine. Microsoft failed to identify and prevent the use of its products by prohibited parties. Microsoft voluntarily disclosed...

General

12 Apr, 2023

Uphold HQ Settles OFAC Violations for $72,230

Uphold is a California-based money service business. Uphold agreed to pay OFAC $72,230 to resolve multiple sanctions program violations. Between March 2017 and Maay 2022, Uphold and its affiliates processed 152 transactions totaling $180,5765 in violation of the Iran, Cuba and Venezuela sanctions programs. The customers involved in the illegal transactions self-identified as being located in Cuba or Iran and for employees of the Venezuela...

General

12 Apr, 2023

Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II)

Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations. According to OFAC, Microsoft demonstrated a reckless disregard for U.S. sanctions by failing to identify that over a seven-year period, more than $12,000,000 worth of software and services were exported from the United States through Microsoft systems and servers...

General

10 Apr, 2023

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

OFAC announced only one settlement in the first three months of 2023. Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable. The situation changed, however, in the first week of April 2023 – OFAC announced two enforcement actions: a major action against Microsoft and another against Uphold HQ, Inc. (“Uphold”), a U.S. money service...

Podcasts

10 Apr, 2023

Episode 269 — Deep Dive into the Wells Fargo OFAC Sanctions Settlement

Wells Fargo added to its Grand Slam of Enforcement with its recent settlement of OFAC violations and paid $30 million to settle the matter. Wells Fargo’s violations occurred during a seven-year period, 2008 to 2015, and stemmed from its acquisition of Wachovia Bank. Wells Fargo provided a foreign bank (part of predecessor Wachovia) with trade-finance software that Wachovia used to process trade financing transactions with...