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Economic Sanctions Civil Monetary Penalty

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

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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

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Ropes & Gray LLP

OFSI Annual Review 2023-2024: A Shift Towards Proactive Sanctions Enforcement and Enhanced Industry Engagement

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On 21 March 2025, the Office of Financial Sanctions Implementation (OFSI) published its annual review for 2023-2024 period. The report highlights a number of key developments in the agency’s work. Importantly, the data...more

The Volkov Law Group

Córdoba Music Group Settles with OFAC for $41,591 for Violations of Iran Sanctions Program

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Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

K&L Gates LLP

UK Office of Trade Sanctions Implementation New Enforcement Powers and Increased Reporting Obligations

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On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more

The Volkov Law Group

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

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In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

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As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Mayer Brown

UK Government Launches Office of Trade Sanctions Implementation to Enforce UK Trade Sanctions

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On 12 September 2024, the UK Government published the regulatory framework providing the scope and powers of the Office of Trade Sanctions Implementation (OTSI), the authority responsible for the implementation and...more

Adams & Reese

International Compliance Digest - June 2024

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Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Vinson & Elkins LLP

The SEC Aces Its Report Card: Enforcement Activity Maintains Record Pace in 2023

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On November 14, the Securities and Exchange Commission (“SEC”) published its 2023 annual enforcement report which revealed a continuation of 2022’s record-setting enforcement activity.1 The SEC imposed $4.95 billion in...more

The Volkov Law Group

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

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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

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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

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

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On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

Torres Trade Law, PLLC

OFAC and BIS Announce Microsoft Settlement of Sanctions and Export Control Violations

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On April 6, 2023, the Department of Treasury Office of Foreign Assets Control (“OFAC”) and the Department of Commerce Bureau of Industry and Security (“BIS”) announced a settlement with Microsoft Corporation (“Microsoft”) and...more

Seward & Kissel LLP

Economic Sanctions in the Shipping Industry: 2022 Highlights

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Shipping companies should remain focused on sanctions compliance for 2023. The sanctions space has been bursting with activity as a result of the Russia-Ukraine war, which shows no signs of abating. Companies continue to seek...more

Holland & Knight LLP

OFAC Increases Civil Monetary Penalties for 2023

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is increasing each civil monetary penalty within its jurisdiction for 2023 by 7.7 percent. The increases came into effect on Jan. 13, 2023.1 Note...more

Oberheiden P.C.

Recent Developments in BIS Charging Letter Protocols Could Damage Your Company’s Reputation

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The Bureau of Industry and Security (BIS) in the United States Department of Commerce has experienced a surge in recognition and importance over the past year. This Bureau, and particularly the Office of Export Enforcement...more

Perkins Coie

FCC Prioritizes Enforcing Transfer of Control and Foreign Ownership Rules

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According to a settlement with the Federal Communications Commission (FCC) announced on October 20, 2022, Truphone Inc. repeatedly transferred control of its FCC licenses to unvetted foreign individuals and entities without...more

Cohen & Gresser LLP

Sanctions Enforcement in England & Wales

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On 8 June 2022, and to coincide with the introduction of amendments to the Economic Crime (Transparency and Enforcement) Act 2022 (“the Economic Crime Act”), the UK’s Office of Financial Sanctions Implementation (“OFSI”)...more

Faegre Drinker Biddle & Reath LLP

Ransomware Payments Become an Even Riskier Choice Amidst the Ever-Growing Sanctions List

In February 2022, Executive Order 14024 highlighted that Russia’s invasion of Ukraine threatened not only Ukraine but also the national security and foreign policy of the United States. Pursuant to this executive order, and...more

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