News & Analysis as of

Corporate Counsel Office of Foreign Assets Control (OFAC) Civil Monetary Penalty

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

Troutman Pepper Locke on

On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more

The Volkov Law Group

OFAC Settlement with DaVinci Payments Is Wake-Up Call for Prepaid Access Industry

The Volkov Law Group on

Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more...more

Oberheiden P.C.

Insights from OFAC Enforcement Actions So Far

Oberheiden P.C. on

Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more

BCLP

SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business...

BCLP on

On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more

Snell & Wilmer

Federal Court Rescinds $2 Million OFAC Penalty Against Exxon: Lessons Learned in Seeking Guidance for International Transactions

Snell & Wilmer on

On New Year’s Eve, a federal court relieved ExxonMobil of a $2 million fine levied against the company by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC imposed the penalty against Exxon for...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $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

Jones Day

Sanctions Enforcement Action Provides Incentives for Companies and a Warning for Individuals

Jones Day on

The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more

Parker Poe Adams & Bernstein LLP

U.S. Government Continues Raising the Cost of Noncompliance

The U.S. Justice Department, the Federal Trade Commission, and other federal agencies recently announced their 2018 increases for civil penalties. As the costs of violations continue rising, it is imperative that companies...more

Sheppard Mullin Richter & Hampton LLP

A New Sleuth in Britain: The UK Quietly Empowers a Sanctions Enforcement Office

On April 3, 2017, the UK Treasury’s Office of Financial Sanctions Implementation (OFSI) announced new penalties for economic sanctions violations of £1 Million or 50% of the value of the transaction, whichever is higher. As a...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Davis Wright Tremaine LLP

Violation of OFAC Reporting Requirements: “No Harm, No Foul”? No Way!

A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...more

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