News & Analysis as of

Office of Foreign Assets Control (OFAC) Enforcement Actions Penalties

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

The Volkov Law Group

Episode 378 — Update on Export and Sanctions Enforcement Cases

The Volkov Law Group on

The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

The Volkov Law Group on

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more

Foley Hoag LLP

Lessons from the First Four OFAC Sanctions Enforcement Actions under the Second Trump Administration

Foley Hoag LLP on

Key Takeaways: - After a 5-month pause, OFAC recently announced four sanctions enforcement actions, making clear it is rigorously enforcing sanctions violations across a wide range of programs (including Russia, Iran,...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

The Volkov Law Group

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more

Amundsen Davis LLC

How to Be Removed From a U.S. Sanctions Watchlist List

Amundsen Davis LLC on

U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial,...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Kilpatrick

8 Key Takeaways | Part Two -- 2024 Roundup: Key Takeaways from U.S. Sanctions Enforcement Actions and 2025 Predictions

Kilpatrick on

Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2024

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You are reading the November 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

Foley & Lardner LLP on

Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Harris Beach Murtha PLLC

Cryptocurrency: In the Face of Increased Enforcement, Be Prepared

This summer was a busy one for cryptocurrency regulators, with aggressive actions potentially signaling an increase in consumer protection compliance activity. In August alone, the New York Department of Financial Services...more

Bracewell LLP

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

Bracewell LLP on

In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Husch Blackwell LLP

Increased OFAC Penalties For Companies Lacking Sanctions Compliance Programs

Husch Blackwell LLP on

Key Points- Members of the international business community who are subject to U.S. trade sanctions and who have non-existent or inadequate sanction compliance programs (SCPs) are now potentially subject to significantly...more

Akin Gump Strauss Hauer & Feld LLP

The Export Control Reform Act and Possible New Controls on Emerging and Foundational Technologies

• ECRA became law on August 13, 2018. It is the permanent statutory authority for the EAR, which is administered by the U.S. Department of Commerce’s BIS. The new law codifies long-standing BIS policies and does not require...more

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

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•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Pushes New Limits on Jurisdiction of U.S. Sanctions by Penalizing Non-U.S. Companies for “Causing” Violations by Making U.S....

On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more

Bass, Berry & Sims PLC

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

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It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

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