OFAC, BIS Double Up Flow Serve: What the Flowserve Settlement Says About Corporate Compliance Programs

In late September, Flowserve Corporation (“Flowserve”) and a number of its subsidiaries agreed to settle alleged export violations with the Department of Commerce, Bureau of Industry of Security (“BIS”) for $2.5 million, and to remit $502,408 to the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) to settle alleged U.S. sanctions violations. Flowserve, including its subsidiaries, is an oil, gas, and chemical services company with operations around the world. The settlement underscores the value of compliance measures specifically tailored to a company's operations, and provides yet another example of the U.S. government vigorously enforcing U.S. law overseas.

Export. The Export Administration Regulations (“EAR”), administered by BIS, govern exports and re-exports of U.S.-origin commodities, technology, and software. In a series of agreements, Flowserve and its subsidiaries settled alleged BIS violations involving...

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