News & Analysis as of

Exports Office of Foreign Assets Control (OFAC) Sanction Violations

Ankura

Russian Sanctions Circumvention: Are You Asleep At The Wheel?

Ankura on

In the wake of Russia's invasion of Ukraine in February 2022, a broad and unprecedented range of sanctions were imposed on Russia by various countries and international bodies to target the Russian economy and prevent further...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

Locke Lord LLP on

On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

The Volkov Law Group on

In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....more

Adams and Reese LLP

International Compliance Digest – April 2024

Adams and Reese LLP on

April was another month of robust trade actions aimed at foreign goods, export compliance, and heightened enforcement powers. DHS issued an enhanced strategy policy on the textile industry with a focus on de minimis...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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2024 Update

Bass, Berry & Sims PLC on

February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...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

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

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

Dunlap Bennett & Ludwig PLLC

Navigating Restricted Parties Lists in the United States: Screening to Facilitate Compliance

Under the U.S. Export Administration Regulations (EAR), Part 736 General Prohibition #5 (EAR 736.5) imposes restrictions on certain activities related to exports, reexports, and transfers (in-country) of items subject to the...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

Bass, Berry & Sims PLC on

July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

The Volkov Law Group on

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

Latham & Watkins LLP

US Sanctions and Export Control Agencies Issue “Joint Compliance Note” on Voluntary Self-Disclosure Policies

Latham & Watkins LLP on

Companies that promptly self-disclose and remediate potential violations of administrative or criminal law may significantly mitigate liability. On July 26, 2023, the US Departments of Justice (DOJ), Commerce, and the...more

Holland & Knight LLP

Tri-Seal Compliance Note Issued on Export Controls, Sanctions Violations Self-Disclosures

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more

The Volkov Law Group

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

The Volkov Law Group on

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

American Conference Institute (ACI)

[Event] European Forum on Global Economic Sanctions - June 1st - 2nd, Berlin, Germany

Hosted by C5 Group, the European Forum on Global Economic Sanctions is recognized as Europe's Premier, longstanding gathering for financial institutions and global exporters. The industry across Europe is confronting an...more

The Volkov Law Group

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

The Volkov Law Group on

OFAC announced only one settlement in the first three months of 2023.  Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable.  The...more

American Conference Institute (ACI)

[Event] 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance - April 25th - 26th, Washington, DC

The American Conference Institute is hosting their 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance on April 25-26, 2023, in Washington! Don’t miss the opportunity to stay current with the...more

Eversheds Sutherland (US) LLP

Services ban and EU import ban come into effect for seaborne Russian petroleum products

On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

Torres Trade Law, PLLC on

Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

The Volkov Law Group

DOJ and OFAC Settle with Indonesian Company for $2.5 Million for Violations of the North Korea Sanctions Program

The Volkov Law Group on

PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for...more

Kilpatrick

4 Key Takeaways - OFAC Enforcement Actions From June to September 2020

Kilpatrick on

From June through mid-September of 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published six settlements of apparent sanctions violations (Check out our previous Four Key Takeaways...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Sanctions Compliance Guidance Released for the Global Maritime, Energy and Metals Sectors

- On May 14, 2020, OFAC, the Department of State and the U.S. Coast Guard jointly released guidance for persons involved in the maritime industry regarding common deceptive shipping practices used to subvert U.S. and United...more

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