News & Analysis as of

Office of Foreign Assets Control (OFAC) Financial Transactions Enforcement Actions

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

Troutman Pepper Locke on

We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

The Volkov Law Group on

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....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

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

The Volkov Law Group on

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

Ballard Spahr LLP on

Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Orrick, Herrington & Sutcliffe LLP

OFAC reaches $508 million settlement with British tobacco company on North Korean transactions

On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement with one of the world’s largest tobacco companies to resolve potential civil liabilities stemming from...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

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

The Volkov Law Group on

Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

The Volkov Law Group

Wells Fargo Pays OFAC $30 Million to Settle Sanctions Violations (Part I of II)

The Volkov Law Group on

In our lifetime (however long or short), there is no way any company will ever match Wells Fargo for its record of misconduct, criminal and civil enforcement, and regulatory fines and penalties.  No one, no way....more

White & Case LLP

Bitzlato Founder Charged With Facilitating Money Laundering of More than $700 Million in Dark Web Funds

White & Case LLP on

Anatoly Legkodymov, Russian founder of Hong Kong-registered cryptocurrency exchange Bitzlato Limited ("Bitzlato"), was arrested on January 17 based on an Amended Complaint filed by the Department of Justice ("DOJ") charging...more

Orrick, Herrington & Sutcliffe LLP

OFAC settles with Danish company for routing prohibited financial transactions though a U.S. bank

On December 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a more than $4.3 million settlement with a multinational Danish manufacturer to resolve allegations that its wholly owned United...more

The Volkov Law Group

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

The Volkov Law Group on

Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

The Volkov Law Group

OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus...more

Cadwalader, Wickersham & Taft LLP

Lessons Learned from Recent OFAC Enforcement Actions

Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more

The Volkov Law Group

OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions

The Volkov Law Group on

Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front.  Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more

Torres Trade Law, PLLC

OFAC Sends Clear Message to Parties Conducting Business with Entities on OFAC’s Sectoral Sanctions Identification List

Torres Trade Law, PLLC on

As the U.S. and the European Union continue to impose new sanctions on Russia in response to the invasion of Ukraine, regulatory authorities continue their pursuit of companies and individuals who violate those sanctions. The...more

Robinson+Cole Data Privacy + Security Insider

Global Law Enforcement Win: Germany Shuts Down Hydra and U.S. Department of Treasury Follows With Sanctions

In a win for global law enforcement, Germany’s Bundeskriminalamt (BKA) announced on April 5, 2022, that it had officially taken down the infrastructure of Hydra, a Russian-based, illegal dark-web marketplace that has...more

The Volkov Law Group

OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program

The Volkov Law Group on

In May 2019, OFAC released its Framework for a Sanctions Compliance Program.  OFAC announced that it intended to increase the prosecution of individuals for sanctions violations.  OFAC has brought two cases against...more

The Volkov Law Group

Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve

The Volkov Law Group on

Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more

Torres Trade Law, PLLC

Crypto Crackdown: OFAC Sanctions SUEX Cryptocurrency Exchange

Torres Trade Law, PLLC on

On September 21, 2021, in a first-of-it-kind action, the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) imposed economic sanctions on SUEX OTC, S.R.O. (“SUEX”), a virtual currency exchange, for...more

The Volkov Law Group

First Bank of Romania Settles OFAC Violations for $862,318 (Part IV of IV)

The Volkov Law Group on

The First Bank of Romania and JC Flowers agreed to pay OFAC $862,318 to settle violations of Iran and Syria Sanctions Programs.  First Bank is owned by its U.S. parent, JC Flowers & Company. ...more

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