President Putin is making sure that Russia dominates the early 2022 headlines. As Russia aligns its resources to invade Ukraine, the U.S. and European countries prepare to respond aggressively. It appears that nothing will deter President Putin from continuing forward. Russia has calculated that the risks and response from the West may be worth the upside to Russia. Global companies should prepare for an aggressive...
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 Treasury Department’s Office of Foreign Asset Control (OFAC) rarely backs down. Recently, in response to significant ownership and governance changes, OFAC removed three Russian companies, EN+ Group (EN+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE) from the sectoral sanctions list. (Here). OFAC’s decision to remove the three companies capped the efforts of Russian oligarch, Oleg Daripaska, to modify his ownership and control of...
Since 2014, the United States has put into place a comprehensive set of sanctions against Russia. In response to Russia’s annexation of Crimea and its hostile activities in the Ukraine, President Obama put in place a set of sanctions focused against various sectors of the Russian economy. Since the Trump Administration came to power, Congress enacted additional sanctions, and the Department of Treasury adopted targeted...
How to Implement an Effective Sanctions Compliance Program Tuesday, December 19, 2017 Sign Up Here The Department of Justice and the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) have aggressively enforced comprehensive and complex sanctions statutes and regulations. Global companies have to design and implement an effective sanctions compliance program in order to avoid sanctions enforcement risks. Join Michael Volkov, CEO of The...
The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals. The sanctions program was instituted in 2014 in response to Russia’s invasion of the Ukraine and annexation of Crimea. In August 2017, Congress enacted statues and directed OFAC to implement additional regulations. Congress acted in response to fears that the Trump Administration...
In a bizarre enforcement action, The Treasury Department’s Office of Foreign Asset Control (“OFAC”) assessed a $2 million civil monetary penalty against ExxonMobil (“Exxon”) for violations of the Ukraine sanctions. (Copy Here). OFAC’s enforcement action boiled down to Exxon’s execution of eight legal documents with Igor Sechin, the CEO of Rosneft OAO (“Rosneft”), who is a Specially Designated Nation and Blocked Person on what is...
