Tagged: sanctions

Lessons Learned from the Unicat Settlement (Part III of III)

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement.  It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part foundation of seeking a favorable enforcement resolution.  Also, it emphasizes the importance of securing disclosure credit with the Justice Department since Unicat’s parent received a declination because of its early disclosure and complete cooperation. In stark contrast, the...

Episode 372 — DOJ Applies False Claims Act to Tariff and Trade Violations

Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs.  Corporate leaders and compliance officials are making a serious mistake when they confuse a “pause” in FCPA enforcement to mean a reduction in federal criminal prosecutions.  This Administration has no problem in taking aggressive positions in the legal arena and I would expect...

OFAC Recalibrates Syria Sanctions in Response to Regime Change

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of U.S. economic policy toward Syria. Acting in close coordination with the Department of State’s issuance of a national security waiver under Section 7425 of the Caesar Syria Civilian Protection Act of 2019...

A Dangerous Combination: False Claims Act and Trade Violations (Part II of III)

As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations.  DOJ fully recognizes the power of the False Claims Act as  a powerful enforcement tool when it comes to trade and tariff enforcement.  Add to the mix, the well-established whistleblower or qui tam relator program and you...

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. ...

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...

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...

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...

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...

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...