Tagged: sanctions

General

20 May, 2025

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

 DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties and the absence of a corporate monitor.  DOJ’s changes are another attempt to spur voluntary disclosures.  Over the last ten years, DOJ has step-by-step sought to increase the benefits of voluntary disclosure. ...

General

4 Feb, 2025

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control (“CNC”) machines, for dozens of violations of the Export Administration Regulations (“EAR”). The enforcement action stems from allegations that Haas facilitated the unauthorized export, reexport, or transfer of U.S.-origin machine...

General

23 Jan, 2025

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations. In 2017, OFAC implemented regulatory sanctions derived from the Global Magnitsky Act and its associated Executive Order.  The 2017 Executive Order 13818 declared a national emergency with respect to serious human rights abuses...

General

13 Jan, 2025

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three years, these five subsidiaries provided freight brokerage or transportation services for 82 shipments, to or from Iran, of Iranian- or...

General

9 Jan, 2025

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant.  While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...

Events

5 Dec, 2024

Start the New Year with Two Important Webinars: 2024 FCPA Review (Jan. 7) & 2024 Sanctions Review (Jan. 14)

2024 FCPA Year in Review January 7, 2024, 12 Noon EST SIGN UP HERE FCPA: For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ’s commitment to FCPA enforcement may be questioned. This past year included several significant FCPA enforcement matters — Raytheon, Trafigura, Gunvor and SAP, along with...

General

3 Dec, 2024

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”)....

General

13 Jun, 2024

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily in the “heartland” of misconduct. DOJ, OFAC and BIS are well aware of the broad reach of...

General

12 Jun, 2024

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC have provided helpful guidance to alert companies where risks are likely to increase. Sanctions enforcement involves an off mix of civil and criminal line drawing.  On the civil side, OFAC...

General

30 May, 2024

DXC Technology Company Settles Sanctions and Export Control Violations

On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that previously-disclosed proceedings involving both the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) had been resolved. According to the SEC filing, DXC officially...

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