General
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New
General
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,
Podcasts
The Trump Administration has aggressively restricted commerce with Cuba and Venezuela. With respect to Cuba, the Trump Administration has re-imposed strict regulations on commerce with Cuba, reversing several Obama-era regulations easing such restrictions. At the same time, the Trump Administration has continued Obama era policies tightening trade with
General
I will admit it – I changed this posting from its original draft. I intended to write about the absence of any OFAC enforcement actions for 2018. I went to double-check the OFAC enforcement website (here), and lo and behold, OFAC snuck its first enforcement action of 2018 – dated June
Events
Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program June 12, 2018 12 Noon EST Sign Up Here Sanctions compliance has become more complex and difficult. The Russia-Ukraine Sanctions Program includes detailed sectoral sanctions and comprehensive "oligarch" sanctions against Russia's leading industrial oligarchs. Compliance
General
The Trump Administration Treasury Department’s Office of Foreign Asset Control activity has been interesting to watch. On the one hand, OFAC has been implementing aggressive sanctions against Russia in reaction to Russia’s global misconduct. On the other hand, OFAC has brought -- no, none, zip -- enforcement actions this year.
General
On April 6, 2018, OFAC announced a new round of sanctions against Russian individuals and companies. (For Press Release Here; new FAQs Here; and new General Licenses 12 Here and 13 Here). Relying on its authority under existing executive orders, OFAC designated seven Russian oligarchs and 12 companies they own
General
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually played out in a variety of sanctions regimes and policies. This year, however, saw Congress enter the regulatory fray, when it imposed
Podcasts
Global companies face ever-increasing risks with sanctions screening and compliance. The US Treasury Department's Office of Foreign Asset Control ("OFAC") has aggressively enforced complex sanctions regulations against global companies, including banks, manufacturing, oil service and technology companies. In this aggressive enforcement era, companies have to
General
In a bizarre enforcement action, The Treasury Department’s Office of Foreign Asset Control (“OFAC”) assessed a $2 million civil monetary penalty against ExxonMobil (“Exxon”) for violations of the Ukraine sanctions. (Copy Here). OFAC’s enforcement action boiled down to Exxon’s execution of eight legal documents with Igor Sechin,
General
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