News & Analysis as of

Economic Sanctions Sanction Violations Enforcement Actions

McDermott Will & Emery

Quarterly Sanctions Update | Q3 2024

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Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week,...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

McGuireWoods LLP

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

McGuireWoods LLP on

On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more

The Volkov Law Group

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

The Volkov Law Group on

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...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

The Volkov Law Group on

While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more

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

White & Case LLP

EU establishes harmonized enforcement and penalties for sanctions violations

White & Case LLP on

The EU has adopted a new directive which establishes EU-wide rules for defining criminal offences and penalties related to the violation of EU sanctions. A stricter regulatory environment and closer scrutiny is expected as...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

The Volkov Law Group on

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

The Volkov Law Group

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

The Volkov Law Group on

OFAC is getting ready for a big year.  While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive...more

McGuireWoods LLP

Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

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For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

The Volkov Law Group

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

The Volkov Law Group on

On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more

American Conference Institute (ACI)

[Webinar] Virtual Proficiency Series on Economic Sanctions - February 6th - 29th, 1:30 pm - 4:30 pm EST

ACI’s highly anticipated Proficiency Series on Economic Sanctions provides true immersion into Economic Sanctions with the objective of becoming proficient in 4 weeks. Advance your career and professional development by...more

The Volkov Law Group

Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure

The Volkov Law Group on

When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

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You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

The Volkov Law Group on

As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

Bracewell LLP

DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

Bracewell LLP on

The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

The Volkov Law Group

OFAC Settlement with DaVinci Payments Is Wake-Up Call for Prepaid Access Industry

The Volkov Law Group on

Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more...more

Oberheiden P.C.

Insights from OFAC Enforcement Actions So Far

Oberheiden P.C. on

Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

WilmerHale on

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

The Volkov Law Group

OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure

The Volkov Law Group on

Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

The Volkov Law Group on

The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

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