News & Analysis as of

Sanctions Foreign Subsidiaries

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

Foley Hoag LLP

The Voluntary Disclosure Landscape After Microsoft’s Settlements with BIS and OFAC and the Issuance of the Axelrod Memorandum

Foley Hoag LLP on

On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more

Morrison & Foerster LLP

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

Morrison & Foerster LLP

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

Faegre Drinker Biddle & Reath LLP

New Antidumping and Countervailing Duty Petitions on Utility Scale Wind Towers from Canada, Indonesia, Korea, and Vietnam

The Wind Tower Trade Coalition (“petitioner”), on July 9, 2019, filed antidumping (AD) petitions on imports of certain utility scale wind towers from Canada, Indonesia, Korea, and Vietnam and countervailing duty (CVD)...more

Pillsbury Winthrop Shaw Pittman LLP

European Subsidiary Incurs Liability Under U.S. Cuba Sanctions for Travel Services

On April 18, 2014, the Office of Foreign Assets Control (“OFAC”) announced a settlement of nearly $6 million with CWT B.V. (“CWT”) for violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. Part 515. CWT is a...more

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