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The Volkov Law Group

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

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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

The Volkov Law Group

OFAC Settles with Mondo TV for $538k for Violation of North Korean Sanctions

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OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more

The Volkov Law Group

BIS Issues Denial Order for Domestic Freight Forwarder Alleging Multiple Violations of Settlement Agreement Terms

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On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-based freight...more

Wiley Rein LLP

Wiley's 10 Key Trade Developments: Evolution of Export Controls

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Along with engaging in closer cooperation with partner countries, the U.S. is prioritizing its own national security interests as well, moving first in many respects....more

American Conference Institute (ACI)

[Event] 10th National Conference on CFIUS - April 11th - 12th, Arlington, VA

Hosted by American Conference Institute, the 10th National Conference on CFIUS returns for another exciting year with curated programming that will provide invaluable insights on repositioning your transaction planning amidst...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

BIS Imposes $153,175 Penalty Against Wabtec Corporation to Resolve Multiple Violations of Antiboycott Regulations

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Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

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As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

Whitcomb Selinsky, PC

Strict Liability in FedEx's Appeal: Implications for Export Controls

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In a gripping legal showdown that captivated the nation, the Federal Express Corporation (FedEx) found itself embroiled in a highly contentious dispute with the United States Department of Commerce. At the heart of this...more

Whitcomb Selinsky, PC

Federal Express vs. U.S. Department of Commerce in Appellate Law

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In a riveting legal dispute that unfolded within the realm of appellate law, Federal Express Corporation, known as FedEx, found itself pitted against the U.S. Department of Commerce, alongside various other entities, over the...more

The Volkov Law Group

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

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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

The Volkov Law Group

BIS Ramps Up Antiboycott Enforcement Efforts

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On November 3, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that a settlement had been reached with Forta —a domestic synthetic fiber manufacturer—for its conduct in agreeing to a...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

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Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

The Volkov Law Group

OFAC Ramps Up Price Cap Enforcement as Coalition Publishes Compliance Advisory for Maritime Oil Industry

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It looks like the days of Russia’s so-called “shadow fleet” are numbered. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced Thursday that it had imposed sanctions on two entities, and...more

The Volkov Law Group

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

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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

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

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The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

BIS Signals New Enforcement Initiative for Antiboycott Compliance — Pratt and Whitney Settles Antiboycott Violations

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On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

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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

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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

The Volkov Law Group

OFAC Settles with Construction Specialties, Inc. for $660,594 for Violations of Iran Sanctions

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Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more

The Volkov Law Group

Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k

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Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million.  Murad was acquired by Unilever United...more

Orrick, Herrington & Sutcliffe LLP

OFAC reaches $3.3 million settlement with cosmetics company for Iranian sanctions violations

The U.S Treasury Department’s Office of Foreign Assets Control (OFAC) recently announced settlements with a California-based cosmetics company and a former senior company executive to resolve potential civil liability...more

The Volkov Law Group

Corporate Crime and National Security – The Confluence of Prosecution and Foreign Policy (Part I of III)

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To restate the obvious – DOJ has prioritized prosecution of national security crimes.  For the business world, every company touches the international economy.  Even a domestic company might sell products or services outside...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions chemical suppliers tied to Mexican drug cartel

On April 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14059, against two Chinese entities and five individuals based in China and Guatemala for...more

Stikeman Elliott LLP

Canadian Sanctions Update: Recent Regulatory and Judicial Developments

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In this post, we describe the economic sanctions imposed by Canada since our November 5, 2022 update, as well as Russian asset freezing order and a judicial decision in the sanctions law area. We expect more sanctions and...more

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