Trade compliance is the new hot field. Companies are catching up with trade compliance in response to the global sanctions regimes put in place to cripple Russia. The United States, its allies and partners have implemented...more
1/24/2023
/ Anti-Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Relations ,
Ukraine ,
US Trade Policies
OFAC closed out 2022 with a late-night $4.3 million settlement with Danfoss A/S, a Danish manufacturer of refrigeration and cooling products for violations of the Iran, Syria and Sudan sanctions programs. OFAC has had a...more
I admit I may be a little late in completing some of my 2022 retrospective postings. Nevertheless, I have to announce Corruption, Crime & Compliance’s Person of the Year Award. Although my posting is not done with as much...more
The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector. It is even more complicated given...more
Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more
12/9/2022
/ Corruption ,
Crypto Exchanges ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Virtual Currency
On October 21, 2022, the global Financial Action Task Force (“FATF”) added the nation of Myanmar to its so-called “blacklist” of jurisdictions with “strategic deficiencies” in their legal and regulatory regimes that permit...more
The Department of Commerce’s Bureau of Industry and Security promised aggressive enforcement of export controls. BIS’s promise extended beyond the Russian-Belarus export controls. BIS has kept its promise....more
The Department of Justice is pushing its commitment to voluntary disclosure programs. Companies, however, are not lining up at DOJ’s door. The balance between sitting tight or voluntary disclosures requires care....more
The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus...more
On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange based in...more
​​​​​​​On September 30, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) announced a settlement with Tango Card, Inc. (“Tango Card”), a supplier and distributor of stored valued...more
The Office of Foreign Assets Control (“OFAC”) has demonstrated its ability to multi-task — designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining...more
On September 9, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) released “Preliminary Guidance” concerning a ban on maritime transportation services involving Russian Federation...more
It’s been five months since Russia invaded the Ukraine, and the United States has imposed a succession of increasingly severe economic sanctions on Russia and Belarus. A recent study published by Jeffrey Sonnenfeld, a...more
Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC...more
Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front. Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more
7/26/2022
/ American Express ,
Compliance ,
Corruption ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Foreign Narcotics Kingpin Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
SDN List
The Department of Treasury issued additional sanctions against Russia, targeting almost 100 entities and individuals, and prohibited import of Russian gold. The United States’ latest action reflected commitments recently...more
7/11/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Transactions ,
FinCEN ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Gold ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
U.S. Treasury ,
Ukraine ,
Vladimir Putin
Under a statutory instrument promulgated under the Sanctions and Anti-Money Laundering Act 2018 (amending the Russia (Sanctions) (EU Exit) Regulations 2019)), the UK government recently passed sweeping new trade restrictions...more
6/24/2022
/ Crimea ,
Digital Platforms ,
Economic Sanctions ,
Internet ,
Internet Service Providers (ISPs) ,
Military Conflict ,
New Regulations ,
Russia ,
Social Media ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
The Department of Commerce’s Bureau of Industry and Security (“BIS”) charged Russian oligarch Roman Abramovich with violating U.S. export controls by exporting U.S.-origin aircraft to Russia. In a precedent setting action,...more
6/23/2022
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Military Conflict ,
Russia ,
U.S. Commerce Department ,
Ukraine
The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is a busy enforcement agency. OFAC has implemented the comprehensive Russia Sanctions Program in response to Russia’s invasion of the Ukraine. The scope and...more
In its continuing ratcheting of sanctions against Russia, the United States and the European Union have announced new sanctions and export controls to target additional industries and government officials. In a new front,...more
5/12/2022
/ Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine ,
Vladimir Putin
Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions. The dye is cast, so here we go. ...more
5/11/2022
/ Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
FCPA Guidance ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Military Conflict ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Violations ,
Russia ,
Ukraine ,
White Collar Crimes
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
5/3/2022
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Failure to Comply ,
Freight Forwarding ,
Goods or Services ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
SDN List ,
Settlement Agreements
Even while the Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been properly focused on implementing and enforcing the Russia sanctions scheme in response to Russia’s unprovoked invasion of Ukraine, OFAC...more