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The Volkov Law Group

OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions

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North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more

The Volkov Law Group

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

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Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

Mayer Brown

US, EU and UK Adopt New Russia Sanctions and Export Controls as Ukraine War Hits Two-Year Mark

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Following the invasion of Ukraine by Russia on February 24, 2022, the United States ("US"), the European Union ("EU"), and the United Kingdom ("UK") adopted—together with their allies—successive waves of sanctions, in an...more

Cadwalader, Wickersham & Taft LLP

Western Governments Impose Range of New Russia Sanctions with Focus on Sanctions Evaders

The U.S., EU and UK have imposed significant new sanctions and are stepping up enforcement against sanctions evaders on the second anniversary of Russia’s full-scale invasion of Ukraine. On February 23, 2024, the U.S....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

OFAC Begins to Roll Back Venezuelan Sanctions Relief, Again Prohibiting Transactions with CVG Minerven

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Easy come, easy go.  On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...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

The Volkov Law Group

A pesar del alivio en materia de sanciones comerciales por parte del gobierno de EE.UU al sector del petróleo y gas en Venezuela...

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Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more

The Volkov Law Group

Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks

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As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief.  Specifically, OFAC issued General License 44 (among...more

The Volkov Law Group

La Oficina de Control de Activos Extranjeros (OFAC) otorgó alivios a las sanciones comerciales en Venezuela y autorizó ciertas...

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El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more

The Volkov Law Group

OFAC Provides Venezuela with Sanctions Relief, Authorizes Certain Transactions in the Oil and Gas Industry

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On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions.  The relief includes General Licenses...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

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

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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

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more

The Volkov Law Group

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

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In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence...more

Manatt, Phelps & Phillips, LLP

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: May 16, 2022 U.S. economic sanctions against Russian interests continue to build in response to the developing situation between the Russian Federation and Ukraine. Donetsk...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

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Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

Cadwalader, Wickersham & Taft LLP

In Depth: President Biden Proposes New Administrative Forfeiture Process and Other Legislative Changes to Address Ukraine Crisis

Alongside the slew of new sanctions imposed in response to Russia’s invasion of Ukraine, the Biden administration also has been laying the groundwork to maximize the impact of those sanctions. Just days after Russian military...more

Manatt, Phelps & Phillips, LLP

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 15, 2022 U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine....more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

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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

OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program

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In May 2019, OFAC released its Framework for a Sanctions Compliance Program.  OFAC announced that it intended to increase the prosecution of individuals for sanctions violations.  OFAC has brought two cases against...more

The Volkov Law Group

NewTek, Inc., a Software Provider, Settles OFAC Violations for $189,483

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The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....more

Kramer Levin Naftalis & Frankel LLP

Biden Administration Issues Directive for Revitalized Strategies to Combat Corruption and Financial Crime, Signaling Increased...

On June 3, 2021, President Biden issued the first National Security Study Memorandum of his presidency, in which he declared fighting corruption “a core United States national security interest.” The Memorandum sets out the...more

The Volkov Law Group

Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program

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The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions.  As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is...more

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