News & Analysis as of

Iran Sanctions Economic Sanctions Sanction Violations

The Volkov Law Group

OFAC’s Stated Concern About Foreign Companies and Domestic Sanctions Compliance and Post-Acquisition Compliance (Party IV of IV)

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Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...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

American Conference Institute (ACI)

[Event] European Forum on Global Economic Sanctions - June 5th - 6th, Berlin, Germany

Hosted by the C5 Group Inc., the 2024 European Forum on Global Economic Sanctions will explore the evolution of the global economic sanctions landscape, analyzing everything from the shifting geopolitics around the globe, to...more

American Conference Institute (ACI)

[Event] 8th Annual Canadian Forum on Global Economic Sanctions - March 6th - 7th, Toronto, ON, Canada

Immerse yourself in the only comprehensive economic sanctions event of its kind in Canada, spanning two days of invaluable insights and practical knowledge. Designed to cover U.S., EU, and major global sanctions, this...more

The Volkov Law Group

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

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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

Orrick, Herrington & Sutcliffe LLP

2nd Circuit: Court upholds dismissal of whistleblower suit alleging Iran sanctions violations

On October 27, the U.S. Court of Appeals for the Second Circuit denied a petition for a panel rehearing en banc in a False Claims Act (FCA) suit that was dismissed in 2020. The whistleblower suit, filed in 2019, alleged...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

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

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

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

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

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

Uphold HQ Settles OFAC Violations for $72,230

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Uphold is a California-based money service business.  Uphold agreed to pay OFAC $72,230 to resolve multiple sanctions program violations....more

Seward & Kissel LLP

Economic Sanctions in the Shipping Industry: 2022 Highlights

Seward & Kissel LLP on

Shipping companies should remain focused on sanctions compliance for 2023. The sanctions space has been bursting with activity as a result of the Russia-Ukraine war, which shows no signs of abating. Companies continue to seek...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

The Volkov Law Group

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

The Volkov Law Group on

Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

The Volkov Law Group

Managing Third-Party Sanctions Risks (Part I of III)

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If there is one issue that is repeated over and over (and over), it is third-party risks.  Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world.  And with this 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

Alfa Laval pays over $432K for Violations of OFAC’s Iran Sanctions Program

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In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran...more

The Volkov Law Group

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

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The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more

The Volkov Law Group

SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)

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When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern....more

The Volkov Law Group

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

The Volkov Law Group on

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

The Volkov Law Group

UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program

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UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions...more

The Volkov Law Group

Avnet Asia Settles Export Control Violations for Illegal Sales to China and Iran

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The Justice Department recently announced a settlement with Avnet Asia for illegal shipments of sensitive U.S. commodities to China and Iran.  Under the settlement, DOJ agreed to a non-prosecution agreement (NPA) in exchange...more

Hogan Lovells

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

Hogan Lovells on

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

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