Episode 315 - Boeing Pays $51 Million for ITAR Violations
Lawyers regularly advise clients on navigating the complex and evolving U.S. sanctions regime enforced by the Office of Foreign Assets Control (“OFAC”). When a business or individual becomes aware of a potential violation of...more
2022 saw a big shift in the geo-political climate and a bedding in of the new hybrid working world. These two developments are reflected in the blogs our subscribers were most interested in reading. Readers remain focused on...more
On 8 June 2022, and to coincide with the introduction of amendments to the Economic Crime (Transparency and Enforcement) Act 2022 (“the Economic Crime Act”), the UK’s Office of Financial Sanctions Implementation (“OFSI”)...more
Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions. The dye is cast, so here we go. ...more
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 UK-based Bank of China agreed to pay $2.3 million to settle violations of OFAC’s Sudan Sanctions Program. OFAC repealed the Sudan sanctions in October 2017 but is continuing to investigate violations of the Sudan...more
In October, the World Bank Group (WBG) published its third Sanctions System Annual Report for Fiscal Year 2020 (FY20), which covers the period from 1 July 2019 to 30 June 2020. The report provides a detailed look at the...more
Regulators expect companies to investigate actual or potential violations completely and to disclose the nature and scope of those violations completely, in order to obtain credit for their disclosures. Identifying violations...more
OFAC continues to aggressively enforce its sanctions programs. In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more
On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more
In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia...more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more
The revised policy both clarifies and expands DOJ’s prior disclosure guidance. On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape. Global companies now face a complex regime of sanctions that require careful navigation....more
I will admit it – I changed this posting from its original draft. I intended to write about the absence of any OFAC enforcement actions for 2018. I went to double-check the OFAC enforcement website, and lo and behold, OFAC...more