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Distributors Enforcement Actions Office of Foreign Assets Control (OFAC)

The Volkov Law Group

Distribution Chains and Sanctions Compliance (Part II of IV)

The Volkov Law Group on

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment.  Additionally, companies may maintain parallel sales activities in markets between their...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

Kelley Drye & Warren LLP

Distributor danger: OFAC case highlights sanctions liability for bad acts by distributors and foreign subsidiaries

Kelley Drye & Warren LLP on

Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

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