The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
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
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more
Malicious Android Apps Used to Target Iranian Banks - An ongoing Android malware campaign targeting users of Iranian financial institutions has expanded to include new abilities to target an even greater number of people...more
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 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
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 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
Uphold is a California-based money service business. Uphold agreed to pay OFAC $72,230 to resolve multiple sanctions program violations....more
President Joe Biden signed into law the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (2023 NDAA or Defense Bill) on Dec. 23, 2022. The Defense Bill, which passed the U.S. House of Representatives on...more
The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more
In this post we describe the sanctions recently imposed by Canada on Iranian individuals and entities following the detention and, according to the Canadian government, apparent killing of Mahsa Amini, an Iranian woman, in...more
Editor’s Note: On July 27, 2022, HaystackID shared an educational webcast on the topic of Committee on Foreign Investment in the United States (CFIUS) compliance. CFIUS is a U.S. government interagency committee with the...more
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 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
Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more
On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more
In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more
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
It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more
What a year for OFAC – Amazon settled its case for OFAC violations and now add Berkshire Hathaway. Lat year, Apple settled with OFAC for sanctions violations....more
Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - The United States argued before the United Nations (UN) that Germany, France and the United Kingdom must support the U.S. demand to reimpose UN sanctions on...more
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
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. ...more
Report on Supply Chain Compliance 3, no. 7 (April 2020) The United States Department of the Treasury’s Office of Foreign Assets Control has stayed busy during the coronavirus outbreak. The office made several new additions...more
Despite the sobering news reports on the global spread of COVID-19, companies are continuing to try to conduct operations as (relatively) normally as possible. International business is particularly affected given the...more