On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights...more
12/3/2021
/ Biden Administration ,
Corruption ,
Economic Sanctions ,
Ethiopia ,
Exports ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Popular
As diplomatic tensions between Washington and Beijing continue to escalate, U.S. owned businesses dependent on the sale and export of more sensitive advanced technologies to the People’s Republic of China (“PRC”) should take...more
Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more
11/23/2021
/ Cease and Desist Orders ,
Compliance ,
Consent Order ,
Corruption ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Federal Reserve ,
Financial Services Industry ,
Financial Transactions ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Sudan ,
White Collar Crimes
We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering...more
11/4/2021
/ Crypto Exchanges ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Data Breach ,
Economic Sanctions ,
Hackers ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
NIST ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
SDN List ,
Virtual Currency
We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current...more
This has been an interesting enforcement year. The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of...more
In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”),...more
In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former...more
10/1/2021
/ Arctic Drilling ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Goods or Services ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Offshore Drilling ,
Oil & Gas ,
Russia ,
Sanction Violations ,
Suppliers ,
Supply Contracts ,
Ukraine
The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....more
9/20/2021
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
White Collar Crimes
The First Bank of Romania and JC Flowers agreed to pay OFAC $862,318 to settle violations of Iran and Syria Sanctions Programs. First Bank is owned by its U.S. parent, JC Flowers & Company. ...more
The United States, the United Kingdom, the European Union, Canada and Switzerland have adopted or expanded sanctions against Belarus, and the Alexander Lukashenko regime. ...more
The UK-based Bank of China agreed to pay $2.3 million to settle violations of OFAC’s Sudan Sanctions Program. OFAC repealed the Sudan sanctions in October 2017 but is continuing to investigate violations of the Sudan...more
There are lots of life lessons to apply from Greek Mythology. The classic character Sisyphus, who was punished by Zeus for his trickery and condemned for eternity to push a large boulder up a hill, reminds us of the...more
Companies with supply chains stretching into China and Xinjiang are facing a mountain of compliance challenges. Over the summer, the Biden Administration has taken numerous aggressive steps to pressure China to address human...more
In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran...more
The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more
5/6/2021
/ Anti-Corruption ,
Cloud Computing ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Software ,
Third-Party Service Provider
When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern....more
5/4/2021
/ Anti-Corruption ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Software
In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more
5/3/2021
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Software
Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program. Alliance Steel is a designer and manufacturer of prefabricated steel structures....more
Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and...more
4/23/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Compliance ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Military End Use
The Biden Administration announced new and significant trade sanctions against Russia. The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s...more
4/20/2021
/ Biden Administration ,
Crimea ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds
The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions. As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is...more
3/30/2021
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
White Collar Crimes
UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions...more
3/18/2021
/ Economic Sanctions ,
Enforcement Actions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
Settlement Agreements ,
Supply Contracts
Federal prosecutors take an oath to execute their duties faithfully. Yet, like all professions, some federal prosecutors have violated this oath. For years, prosecutorial misconduct has come under heightened scrutiny. Do not...more
3/3/2021
/ Commerzbank ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Economic Sanctions ,
Evidence ,
Evidence Codes ,
Failure To Disclose ,
FBI ,
Federal Prosecutors ,
Iran Sanctions ,
Legal Ethics ,
Money Laundering ,
Prosecutorial Abuse ,
White Collar Crimes
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
2/24/2021
/ Bitcoin ,
Crimea ,
Cuba ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Iran ,
Merchants ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Payment Processors ,
Sanction Violations ,
SDN List ,
Sudan ,
Syria