News & Analysis as of

Office of Foreign Assets Control (OFAC) Compliance Corporate Counsel

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...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

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...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

Holland & Knight LLP

International Trade Compliance Year in Review: 10 Enforcement Lessons from 2022

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In the past year, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of State's Directorate of...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...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

Fenwick & West LLP

Guidance for the Virtual Currency Industry; 2021 Sanctions Review Shows Increasing Focus on Digital Transactions

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

Perkins Coie on

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

American Conference Institute (ACI)

[Complimentary Webinar] Mitigating Sanctions and Export Control Risks for Life Sciences, Research Institutes and Universities -...

Global life sciences companies, research institutes, and universities face unique challenges when complying with U.S. and non-U.S. trade control laws, including complying with general and specific licenses authorizing...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

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

The Volkov Law Group on

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

American Conference Institute (ACI)

[Virtual Event] Asia Pacific Conference on Economic Sanctions Compliance and Enforcement - May 27th - 28th, 9:00 am - 1:15 pm SGT

ACI’s Asia-Pacific Advanced Conference on Economic Sanctions Compliance and Enforcement is the largest sanctions gathering in Asia for financial institutions and global exporters. This unique conference features senior...more

Morrison & Foerster LLP

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Middle East and Africa Regional Compliance & Ethics Conference - February 11th, 8:55 am - 2:00 pm GST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...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

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

The Volkov Law Group on

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

A&O Shearman

DOJ Offers Non-Prosecution Agreements And No-Fines For Self-Reporting Export Control And Sanctions Violations

A&O Shearman on

In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...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

The Volkov Law Group

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

The Volkov Law Group on

On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule published in the Federal Register greatly expands the...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

The Volkov Law Group on

On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Alston & Bird

Doubling Down on Compliance: OFAC Follows DOJ’s Lead by Issuing Guidance on Corporate Compliance Programs

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The Office of Foreign Assets Control has provided five components and 10 common pitfalls of sanctions compliance programs. Our International Trade & Regulatory and White Collar, Government & Internal Investigations teams...more

Latham & Watkins LLP

OFAC’s 5 Essential Components of an Effective Sanctions Compliance Program

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OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program. On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more

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