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Office of Foreign Assets Control (OFAC) Internal Controls Economic Sanctions

Stankie Law

Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers

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On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more

Foley & Lardner LLP

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

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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

Holland & Knight LLP

Restraining the Kraken: Another Crypto Company Under OFAC Scrutiny

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more

Bracewell LLP

Check It Once, Check It Twice: OFAC Requests Daily Screenings of SDN List for Sanctions Compliance

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A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation: Senior...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

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

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You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program.  But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more

Guidepost Solutions LLC

Is Your Russia–Ukraine And Overall Sanctions Compliance Program Really Working? (Don’t Find Out the Hard Way)

How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...more

The Volkov Law Group

OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program

The Volkov Law Group on

OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more

Bass, Berry & Sims PLC

OFAC Enforcement Update: Settlements Show Value of Internal Controls, Disclosure

Bass, Berry & Sims PLC on

On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

Foodman CPAs & Advisors

OFAC Puts Virtual Currency Industry on Notice

In a new Sanctions Compliance Guide, The Office of Foreign Assets Control (OFAC) of the U.S. Treasury reiterates that compliance obligations apply equally to transactions involving virtual currencies and those involving...more

A&O Shearman

Sanctions Compliance Guidance for the Virtual Currency Industry and updated frequently asked questions

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In response to the rapid growth of virtual currencies, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently published Sanctions Compliance Guidance for the Virtual Currency Industry (“Guidance”)....more

Proskauer - Blockchain and the Law

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

The Volkov Law Group

The Elevation of Sanctions Compliance

The Volkov Law Group on

This has been  an interesting enforcement year.  The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of...more

Nossaman LLP

How to Prevent an OFAC Sanction When Responding to a Ransomware Attack

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A ransomware attack is a major threat affecting all sectors of business, including healthcare. Organizations typically follow state and federal privacy laws as part of their ransomware prevention and response measures....more

K2 Integrity

SPACs and Sanctions: Due Diligence Considerations

K2 Integrity on

Economic sanctions have been increasingly used by countries and international organizations as a tool of foreign policy and national security. This increase in the use of sanctions, particularly by the U.S. Department of the...more

K2 Integrity

What the Biden Administration Brings on Sanctions

K2 Integrity on

Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more

The Volkov Law Group

Five Basic Steps to Implement a Sanctions Compliance Program

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Companies have to implement a sanctions compliance program (SCP).  When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent.  Too many companies are behind the 8-ball...more

The Volkov Law Group

OFAC Screening and Internal Controls

The Volkov Law Group on

Companies have had over one year to review and implement a sanctions compliance guidance program.  This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more

Morrison & Foerster LLP

OFAC Penalizes Communications Systems Exporter For Sudan Sales And Related Services

On September 17, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) reached a $894,111 settlement with Comtech Telecommunications Corp. (“Comtech”) and its subsidiary Comtech EF Data Corp. (“EF...more

K2 Integrity

Applying Expensive Lessons Learned: The Importance of an Effective Sanctions Compliance Program

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For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...more

Foodman CPAs & Advisors

El Programa de Cumplimiento de Sanciones de la OFAC le aplica a todos

OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los...more

Foodman CPAs & Advisors

The OFAC Sanctions Compliance Program applies to all

OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals.   ...more

The Volkov Law Group

Five Common Weaknesses in OFAC Sanctions Compliance Programs

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As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs.  Many companies already have a screening...more

The Volkov Law Group

Five Important Mandates from OFAC Compliance Framework

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Based on its aggressive enforcement program and its recently issued Framework for Sanctions Compliance Programs, OFAC has established a new era in sanctions compliance.  Trade compliance is often siloed into its own...more

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