The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more
7/22/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Cuban Assets Control Regulations (CACR) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Huawei ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws?
In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more
What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it?
Can a robust post-acquisition response really save a parent company from prosecution?
In this episode, Michael...more
The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more
DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more
In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more
6/24/2025
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Sanction Violations ,
U.S. Treasury ,
Ukraine ,
Venture Capital ,
White Collar Crimes
Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding. The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
2/25/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
SDN List ,
Supply Chain
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky...more
2/5/2025
/ Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fines ,
Fraud ,
Guilty Pleas ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
White Collar Crimes
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
1/24/2025
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Sanction Violations ,
US Trade Policies ,
Voluntary Disclosure
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....more
1/23/2025
/ Anti-Corruption ,
Blocked Person ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
Global Magnitsky Act ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Sanctions ,
SDN List ,
Settlement ,
Statutory Violations ,
U.S. Treasury ,
White Collar Crimes
Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more
1/22/2025
/ Anti-Corruption ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
White Collar Crimes
How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025?
In this episode of Corruption, Crime, and Compliance, Michael...more
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...more
1/14/2025
/ Acquisition Agreements ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ports ,
Regulatory Requirements ,
Risk Management ,
Sanction Violations ,
Settlement ,
Shipping
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...more
1/9/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations
The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and...more
11/13/2024
/ China ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trade Retaliation ,
Trump Administration ,
Ukraine ,
US Trade Policies
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more
9/26/2024
/ Audits ,
Compliance ,
Cosmetics ,
Due Diligence ,
Enforcement Actions ,
Goods or Services ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Suppliers ,
Supply Chain
We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more
The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more
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...more
OFAC has been busy and not so busy — what do I mean?
OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more
Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks.
Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more
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...more