Companies involved in export and import activities face a variety of risks from sanctions and export controls created by a complex maze of regulations and oversight from the Department of State, Department of Treasury and the Department of Commerce.  With the increasing complexity of sanctions regimes, companies have to devote significant attention and resources to implement an effective trade compliance program. In this episode, Michael...

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) had a busy year — the first half of 2018 was dedicated to re-imposing the Iran Sanctions Program and updating the Russia Sanctions Program. In the second half of the year, OFAC resumed its pace for enforcement actions. In this episode, Michael Volkov reviews OFAC enforcement actions and sanctions regulations for 2018.

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement program. Thus far, OFAC has collected approximately $270 million in civil penalties, and participated in several major criminal investigations, including Commerzbank and Schlumberger. Commerzbank agreed to pay a total of $1.45 billion...