Podcasts
The Treasury Department's Office of Foreign Asset Control ("OFAC") had a busy year -- the first half of 2018 was dedicated to re-imposing the Iran Sanctions Program and updating the Russia Sanctions Program. In the second half of the year, OFAC resumed its pace for enforcement
General
The Treasury Department’s Office of Foreign Asset Control (OFAC) rarely backs down. Recently, in response to significant ownership and governance changes, OFAC removed three Russian companies, EN+ Group (EN+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE) from the sectoral sanctions list. (Here). OFAC’s decision to remove the
Podcasts
Since 2014, the United States has put into place a comprehensive set of sanctions against Russia. In response to Russia's annexation of Crimea and its hostile activities in the Ukraine, President Obama put in place a set of sanctions focused against various sectors of the Russian economy. Since
Events
How to Implement an Effective Sanctions Compliance Program Tuesday, December 19, 2017 Sign Up Here The Department of Justice and the Department of Treasury's Office of Foreign Asset Control ("OFAC") have aggressively enforced comprehensive and complex sanctions statutes and regulations. Global companies have to design and
Podcasts
The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals. The sanctions program was instituted in 2014 in response to Russia's invasion of the Ukraine and annexation of Crimea. In August 2017, Congress enacted
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,