News & Analysis as of

Corporate Counsel Sanction Violations Compliance

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

WilmerHale on

The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...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

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

BCLP

OFAC to Companies: Don’t Forget Your U.S. Persons

BCLP on

On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more

The Volkov Law Group

OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions

The Volkov Law Group on

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

The Volkov Law Group

General Electric Pays OFAC $2.7 Million for Violations of Cuba Sanctions Program

The Volkov Law Group on

OFAC’s aggressive enforcement program continues to bear fruit.  The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program. So...more

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