News & Analysis as of

Sanction Violations Penalties Economic Sanctions

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

White & Case LLP

EU establishes harmonized enforcement and penalties for sanctions violations

White & Case LLP on

The EU has adopted a new directive which establishes EU-wide rules for defining criminal offences and penalties related to the violation of EU sanctions. A stricter regulatory environment and closer scrutiny is expected as...more

NAVEX

The Subtle but Significant Shift at U.S. Justice Department

NAVEX on

In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

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On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

White & Case LLP

OFSI imposes first multi million pound penalty for UK sanctions breach

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The UK sanctions authority, the Office of Financial Sanctions Implementation (OFSI), has announced its first multi million pound fine since its establishment in 2016.  The fine confirms OFSI’s increasing enforcement activity...more

Society of Corporate Compliance and Ethics...

Focus on US economic sanctions compliance: OFAC imposes fines and expects more monitoring

Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more

Husch Blackwell LLP

Increased OFAC Penalties For Companies Lacking Sanctions Compliance Programs

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Key Points- Members of the international business community who are subject to U.S. trade sanctions and who have non-existent or inadequate sanction compliance programs (SCPs) are now potentially subject to significantly...more

Dechert LLP

OFAC Imposes First Penalty for Russia Sectoral Sanctions Violations

Dechert LLP on

On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions...more

Bass, Berry & Sims PLC

OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening

Bass, Berry & Sims PLC on

• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine • Violations identified during pre-acquisition due diligence on contractor • Denied persons screening was conducted but missed prohibited...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Pushes New Limits on Jurisdiction of U.S. Sanctions by Penalizing Non-U.S. Companies for “Causing” Violations by Making U.S....

On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more

Bass, Berry & Sims PLC

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

Bass, Berry & Sims PLC

Lessons from the Historic ZTE Enforcement Action

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On March 7, 2017, Chinese telecommunications company, Zhongxing Telecommunications Equipment Corp. (ZTE), signed on to three separate settlement agreements with the United States, agreeing to pay $892 million for violations...more

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