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Corporate Counsel › Sanction Violations › 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

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

Akin Gump Strauss Hauer & Feld LLP

Commerce Department Signs New Agreement with ZTE Lifting Denial Order in Exchange for Unprecedented Additional Penalties and...

Akin Gump Strauss Hauer & Feld LLP on

• On June 11th, BIS published a superseding settlement agreement with ZTE, levying the largest-ever monetary penalty by BIS against a non-U.S. company and imposing significant additional compliance measures in exchange for...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

Skadden, Arps, Slate, Meagher & Flom LLP on

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

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