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In one of the first enforcement actions of 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control ("CNC") machines, for dozens of violations of the
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OFAC means what it says -- in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations. In 2017, OFAC implemented regulatory sanctions derived from the Global Magnitsky Act and its associated Executive Order. The 2017
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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three
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Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions
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2024 FCPA Year in Review January 7, 2024, 12 Noon EST SIGN UP HERE FCPA: For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ's commitment to FCPA enforcement may be
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By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at dmelendez@volkovlaw.com and Alex can be reached out at acotoia@volkovlaw.com. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with
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We all know what a "core" sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily
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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC have provided helpful guidance to alert companies where risks are likely to increase. Sanctions enforcement
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On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that previously-disclosed proceedings involving both the U.S. Department of Commerce’s Bureau of Industry and
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While OFAC's enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the "reason to know" and affirmative obligations to monitor resale and distribution of products to ultimate users does not appear to be unreasonable or
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Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment. Additionally, companies may maintain parallel sales activities in markets between their own sales staff and third-party distributors, agents, resellers and dealers. It is interesting how certain industries have evolved and
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By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at dmelendez@volkovlaw.com and Alex can be reached out at acotoia@volkovlaw.com. On April 24, 2024, the European Union (“EU”) officially adopted Directive (EU) 2024/1226 on the definition