News & Analysis as of

Goods or Services Economic Sanctions Office of Foreign Assets Control (OFAC)

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

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We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

The Volkov Law Group

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no...more

The Volkov Law Group

Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities

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In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023,  aimed specifically at reminding industry of their...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

K2 Integrity

Sanctions Against Russia: Recent Developments - May 2023

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K2 Integrity delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions Iran’s international UAV procurement network

On March 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a China-based network of five companies and one individual accused of supporting Iran’s unmanned aerial vehicle...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

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As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

Orrick, Herrington & Sutcliffe LLP

OFAC settles with Indian tobacco company on North Korean transactions

On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $332,500 settlement with an India-registered tobacco company to resolve allegations that it “requested payment in U.S. dollars for...more

The Volkov Law Group

Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks

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The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of...more

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

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You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program.  But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more

The Volkov Law Group

OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program

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OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...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

United States, European Union, United Kingdom and Canada Coordinate Further Sanctions Against Belarus

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In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus.  The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions. ...more

The Volkov Law Group

OFAC Implements New Ethiopia Sanctions Program

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On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights...more

The Volkov Law Group

Keeping Track of Third Party Risks – Bribery and Sanctions

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We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current...more

The Volkov Law Group

Former Schlumberger Company Settles OFAC Case for $160k for Violation of Sudan Sanctions (Part II of II)

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In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”),...more

The Volkov Law Group

Cameron Settles OFAC Case for $1.4 Million for Violation of Ukraine-Russia Sanctions (Part I of II)

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In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second,  Schlumberger Rod Lift, Inc., a former...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

The Volkov Law Group

Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program

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Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program.  Alliance Steel is a designer and manufacturer of prefabricated steel structures....more

Society of Corporate Compliance and Ethics...

Matt Silverman on Export Compliance

Few areas of compliance change as rapidly as export controls. People, companies and even countries move on and off the sanctions list. Adding to the complexity, as Matt Silverman, Senior Manager, Compliance & Export Control...more

Society of Corporate Compliance and Ethics...

[Webinar] Complying with U.S. Trade Sanctions: What every U.S. Company Needs to Know to Avoid OFAC’s Wrath - October 8th, 12:00 pm...

Learning objectives: - Overview of US sanctions regimes - To whom US laws apply (e.g. includes foreign subsidiaries; secondary sanctions) - key developments - compliance obligations and elements of an effective sanctions...more

Hogan Lovells

OFAC settles case involving goods with more than de minimis controlled U.S.-origin content

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On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more

The Volkov Law Group

Keysight Technologies Settles with OFAC for $473,157 for Violations of Iran Sanctions Program

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OFAC is a steady enforcement agency.  As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions. ...more

The Volkov Law Group

OFAC Settles Enforcement Action with Individual for $5000

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I often remind readers – government prosecutors regularly tell you what they  plan to do in advance, and then they do it.  So do not be surprised when the government does something they told you they would do....more

The Volkov Law Group

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

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When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks....more

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