The Treasury Department’s Office of Foreign Asset Control (OFAC”) continues its enforcement run. In a recent case against Haverly Systems, Inc., OFAC sent an important reminder to US companies about compliance with the Ukraine-Russia Sectoral Sanctions Program. Haverly paid roughly $75,000 for two violations of the Ukraine-Russia Sectoral Sanctions (SSI). In two transactions, Haverly violated Directive 2 of the Ukraine-Russia the 90-day maturation limitation on...
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