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Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent. Too many companies are behind the 8-ball when it comes to sanctions compliance. The Treasury Department Office
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OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties. In its latest enforcement settlement, Generali Global Assistance, Inc. (“GGA”), a US-based travel assistance services company that provides travel and claims
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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. In May 2019, OFAC issued its Framework for Sanctions Compliance Commitments. As part
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OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions -- Eagle Shipping (here) and Park Strategies (here). Eagle Shipping Eagle Shipping, a Marshall Islands company, headquartered in Stamford, Connecticut, agreed to pay OFAC $1.125 million to settle
Podcasts
OFAC's aggressive enforcement program continues. Recently, OFAC announced settlements with Apollo Aviation and Apple. Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode, Michael Volkov reviews the two cases and the specific lessons learned.
Podcasts
So far in 2019, OFAC is sending a strong message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement, emphasizing compliance with Cuba and Iran sanctions programs, and focusing on US companies that acquire foreign subsidiaries to ensure post-closing compliance with OFAC sanctions
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Jessica Sanderson, Of Counsel at the Volkov Law Group, rejoins us for a posting on OFAC's recent enforcement actions involving Expedia and other cases involving acquisitions of foreign-owned companies. Jessica can be reached at jsanderson@volkovlaw.com. On June 13, 2019, OFAC announced a settlement with Expedia
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Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex. The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind
Podcasts
OFAC is off to a fast start in 2019. It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC's actions and outlines important sanctions
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The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. (Here). This case requires a theme song and there is none better than Truckin (here) from Grateful Dead’s second compilation album -- What a Long Strange Trip its Been. This
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Many companies have been laser-focused on anti-corruption compliance, and with good reason given the risks and consequences of an anti-corruption enforcement action. In doing so, companies have to be careful to avoid ignoring sanctions risks, especially in the ever-evolving nature of sanctions rules and regulations. The