Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) -
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
1/24/2020
/ Aircraft Sales ,
Airlines ,
Apple ,
Aviation Contracts ,
Civil Monetary Penalty ,
Compliance ,
Cross-Border Transactions ,
Economic Sanctions ,
Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) ,
Foreign Suppliers ,
Non-US Entities ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
Sanction Violations ,
Screening Procedures ,
SDN List ,
Settlement ,
Slovenia ,
Software ,
Sudan ,
Supply Chain ,
Ukraine ,
Voluntary Disclosure
• $2 million penalty against Exxon overturned
• Court concluded that OFAC failed to provide clear notice of violative conduct
• Companies are at risk when acting in context of ambiguous agency guidance
At the end of...more
1/22/2020
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Guidance ,
Executive Orders ,
Exxon Mobil ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Prohibited Transactions ,
Reversal ,
Rosneft ,
Russia ,
Sanction Violations ,
SDN List ,
Ukraine ,
Vacated
• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine
• Violations identified during pre-acquisition due diligence on contractor
• Denied persons screening was conducted but missed prohibited...more
12/13/2018
/ Blocked Entities ,
Due Diligence ,
Economic Sanctions ,
Exporters ,
Federal Contractors ,
Foreign Acquisitions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Policies and Procedures ,
Risk Assessment ,
Russia ,
Sanction Violations ,
Screening Procedures ,
SDN List ,
Ukraine ,
Voluntary Disclosure