News & Analysis as of

Penalties Office of Foreign Assets Control (OFAC) Economic Sanctions

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

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

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On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and...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...

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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

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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

WilmerHale

UK Cross-Government Review of Sanctions: Welcome but Unambitious Recommendations for Sanctions Enforcement

WilmerHale on

On 15 May 2025, the UK Government published the conclusions of its cross-government review of UK sanctions implementation and enforcement (the Review)....more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

Lowenstein Sandler LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...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

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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

Bass, Berry & Sims PLC on

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

Whiteford

Client Alert: DOJ and OFAC Actions Showcase Expansive U.S. Oversight of Foreign Conduct

Whiteford on

The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...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

Adams & Reese

International Compliance Digest - September 2024

Adams & Reese on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Ankura

Russian Sanctions Circumvention: Are You Asleep At The Wheel?

Ankura on

In the wake of Russia's invasion of Ukraine in February 2022, a broad and unprecedented range of sanctions were imposed on Russia by various countries and international bodies to target the Russian economy and prevent further...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

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

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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

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...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

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (October 25, 2023)

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A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more

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