News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Subsidiaries Cuban Assets Control Regulations (CACR)

Troutman Pepper Locke

M&A and Global Compliance Lessons From OFAC’s Settlement With Key Holding

Troutman Pepper Locke on

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...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

Bass, Berry & Sims PLC

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

Bass, Berry & Sims PLC on

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

The Volkov Law Group

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

The Volkov Law Group on

With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more

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