News & Analysis as of

Office of Foreign Assets Control (OFAC) Enforcement Guidance

The Volkov Law Group

Commerce Department Tacks to New Aggressive Enforcement Program

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...more

K2 Integrity

OFAC Releases Updated Ransomware Advisory and Announces First Designation of Cryptocurrency Exchange

K2 Integrity on

On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more

The Volkov Law Group

The Urgency of Ethics and Compliance – The Biden Administration and Enforcement

The Volkov Law Group on

The Biden Administration has a lot on its plate – that is obvious.  Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....more

The Volkov Law Group

2020 OFAC Sanctions Enforcement Year in Review (Part I of II)

The Volkov Law Group on

The pandemic and its impact is the story of 2020 – no doubt.  Federal prosecutors and regulatory enforcement agencies faced unprecedented challenges....more

King & Spalding

Patchwork of Cryptocurrency Regulators Increasingly Stitch Together Cooperative Enforcement Efforts

King & Spalding on

Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks - Amid...more

Foodman CPAs & Advisors

¿Sabías que la OFAC y el IRS tienen un Entendimiento?

En Noviembre del 2019, el IRS y la Oficina de Control de Activos Extranjeros (“OFAC”) firmaron un Memorando de Entendimiento (“MOU”).  El MOU describe un entendimiento entre el IRS y la OFAC con respecto a las revisiones...more

Foodman CPAs & Advisors

Did you know that OFAC and the IRS have an Understanding?

In November, 2019 the IRS and the Office of Foreign Assets Control (OFAC) signed a Memorandum of Understanding (MOU).  The MOU outlines an understanding between the IRS and OFAC with respect to reviews conducted by the IRS...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more

WilmerHale

DOJ Revises and Re-Issues Export Control and Sanctions Enforcement Policy for Business Organizations

WilmerHale on

On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more

Williams Mullen

Voluntary Self-Disclosures – An Important Tool for Dealing With Export Violations

Williams Mullen on

It’s a problem that arises in many companies – you suddenly discover that an export violation may have occurred within your company.  It might be a low level violation or it may be a more serious problem, such as the...more

The Volkov Law Group

Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)

The Volkov Law Group on

OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement.  This new approach reflects OFAC’s recent aggressive enforcement programs....more

The Volkov Law Group

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group on

On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance...more

Manatt, Phelps & Phillips, LLP

New OFAC Exposure? What Can Be Learned From Bank's Recent $1.7M OFAC Settlement for Investment-Related Transactions

Why it matters - Swiss-based UBS AG's agreement to pay more than $1.7 million to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) underscores the scope of OFAC sanctions and the complications...more

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