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How the Mighty Have Fallen – Old Testament (2 Samuel 1:19) The Harder They Come, the Harder they Fall – Jimmy Cliff (song) 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
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In yet another enforcement action, OFAC announced a $1.709 million settlement with PACCAR, Inc., for 63 apparent violations of the Iran Sanctions Program by DAF Trucks, a wholly-owned subsidiary based in Eindhoven, Netherlands. (Here). On three separate occasions, between October 2013 and February 2015, DAF sold or supplied
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What a difference a year makes -- The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first enforcement action in June 2018. ELF Cosmetics On January 31, 2019, OFAC announced a $996,
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On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) ended. As part of
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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime, OFAC is beginning to clear some of the enforcement matters that have been pending. JP Morgan
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The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). In doing so, the executive order consolidates relevant sanctions authorities and broadens the scope of the previous
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United States businesses are experiencing a sanctions whipsaw. Since 1979, the President has issued twenty-six Executive Orders restricting trade and commerce with Iran. The Iran Sanctions Program imposed strict prohibitions in a range of areas. The Iran Sanctions Program and the Cuba Embargo are the two most restrict sanctions
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History does not repeat itself but it often rhymes -- Mark Twain (although there is disagreement if Twain uttered these exact words (see here)). Just as businesses were growing or planning to grow into Iran, they had the proverbial rug pulled out from under them. Last week, on May 8, 2018,
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Politics and sanctions law go hand-in-hand. In a rare instance of bi-partisanship, Congress united to constrain the administration’s ability to modify the existing sanctions program against Russia. At the same time, Congress expanded the sanctions regime for Russia, Iran and North Korea. The administration was forced
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Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing. The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary
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Here is a real zinger – clients sometimes do not tell their lawyers the truth. I will wait a minute while you get off the floor because I know everyone is shocked and amazed that this happens. But in the recent ZTE case, which we will discuss, the client company lied
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With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered the sanctions landscape with the Iran Nuclear Treaty, and major changes in its relationship with Cuba and