Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs. ...more
MoneyGram settled with OFAC for $34,329 for 359 sanctions programs violations. MoneyGram is a global payments service.
According to OFAC, the 359 transactions totaled $105,627 in value and were processed on behalf of...more
The Department of Justice’s National Security Division, like its counterpart, the Criminal Division, has made a splash on the enforcement and compliance arena. DOJ has elevated the importance and standing of export and...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
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
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
An often overlooked, but potentially substantial risk factor in a company’s export compliance strategy is the degree to which the company is both familiar with—and adheres to—U.S. Departments of Treasury and Commerce...more
PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for...more
2/19/2021
/ Bank Fraud ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Financial Transactions ,
Fraudulent Wire Transfers ,
Indonesia ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement Agreements ,
Tobacco ,
White Collar Crimes
In the new Biden Administration, companies should expect aggressive enforcement of trade sanctions. At the same time, in response to Russian aggression and the Solar Winds cyber-attack, OFAC is likely to implement new and...more
2/18/2021
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Banks ,
France ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
Syria ,
White Collar Crimes
The Biden Administration has a lot on its plate – that is obvious. Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....more
2/16/2021
/ Biden Administration ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Reform ,
White Collar Crimes
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
The 2020 OFAC enforcement record underscores the importance of sanctions compliance. Yet, companies appear to move slowly in response to sanctions risks, often relying on outdated or outmoded screening technologies and...more
The pandemic and its impact is the story of 2020 – no doubt. Federal prosecutors and regulatory enforcement agencies faced unprecedented challenges....more
OFAC reported two new enforcement actions in the week between Christmas and New Year’s. The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital...more
Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance...more
Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent. Too many companies are behind the 8-ball...more
Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more
What a year for OFAC – Amazon settled its case for OFAC violations and now add Berkshire Hathaway. Lat year, Apple settled with OFAC for sanctions violations....more
OFAC has resumed its aggressive enforcement program. These enforcement actions include: (1) Keysight Technologies settled with OFAC for $473,157 for violations of the Iran Sanctions Program; (2) Comtech Telecommunications...more
OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties....more
10/8/2020
/ Compliance ,
Corporate Counsel ,
Corruption ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Trade Relations ,
White Collar Crimes