News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Subsidiaries

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Foley Hoag LLP

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

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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

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...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

K2 Integrity

SPACs and Sanctions: Due Diligence Considerations

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Economic sanctions have been increasingly used by countries and international organizations as a tool of foreign policy and national security. This increase in the use of sanctions, particularly by the U.S. Department of the...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

Vinson & Elkins LLP

Berkshire Hathaway’s $4.1 Million OFAC Settlement Underscores Risks Of Subsidiaries’ Compliance Failures And Benefits Of Voluntary...

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On October 20, 2020, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had reached a $4.1 million settlement with Berkshire Hathaway, Inc., the multinational conglomerate holding company...more

Kelley Drye & Warren LLP

Takeaways from OFAC’s $4.1 Million Settlement with Berkshire Hathaway

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This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. involving apparent violations of the U.S. embargo on Iran by a subsidiary in Turkey. Under the agreement,...more

Society of Corporate Compliance and Ethics...

[Webinar] Complying with U.S. Trade Sanctions: What every U.S. Company Needs to Know to Avoid OFAC’s Wrath - October 8th, 12:00 pm...

Learning objectives: - Overview of US sanctions regimes - To whom US laws apply (e.g. includes foreign subsidiaries; secondary sanctions) - key developments - compliance obligations and elements of an effective sanctions...more

Foodman CPAs & Advisors

Deficiencies or Weaknesses in an OFAC Sanctions Compliance Program can lead to OFAC Administrative Actions

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

Jones Day

OFAC Dramatically Expands Reporting Obligations

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Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement. On June 21, the...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

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On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

WilmerHale

OFAC Crystallizes Expectations for Sanctions Compliance

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On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

The Volkov Law Group

Stanley Black and Decker Settles OFAC Enforcement Action for $1.9 Million

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Stanley Black and Decker (“Stanley”) and its Chinese subsidiary Jiangsu Guoqiang Tools Co. (“GQ”) agreed to pay approximately $1.9 million to settle OFAC charges that it violated the Iran Sanctions Program. The OFAC...more

Williams Mullen

Company Incurs $7,772,102 Penalty for Dealing With Specially Designated National

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A U.S. company was recently charged with major sanctions violations when its foreign subsidiary entered business transactions with a party listed on the Specially Designated Nationals List. This is a reminder of the...more

The Volkov Law Group

OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions

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The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). ...more

Dechert LLP

The United States Tightens Iran Sanctions by Revoking Authorizations

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The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more

Husch Blackwell LLP

OFAC Officially Revokes Iran General Licenses And Signals Aggressive Enforcement Posture

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On June 27, 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) officially revoked General Licenses H and I. General License H previously allowed foreign owned or controlled subsidiaries of...more

Kelley Drye & Warren LLP

OFAC Formally Rescinds General License H – Foreign Subsidiaries of U.S. Companies Must Withdraw from Iran

Yesterday the Office of Foreign Assets Control (OFAC) formally rescinded General License H, requiring foreign subsidiaries of U.S. companies to wind down remaining business related to Iran by 11:59 pm EST on November 4, 2018....more

Holland & Knight LLP

How Will the United States’ Withdrawal From the Iran Nuclear Accord Affect the Aviation Industry?

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On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more

Perkins Coie

Sanctions Update: Rewind Your Iran Compliance Policy to January 2016

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The United States will reimpose sanctions against Iran to implement President Donald Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a multilateral agreement under which Iran agreed to curb...more

Akin Gump Strauss Hauer & Feld LLP

New Sanctions on Russian Businessmen: Impact on Investment Funds

On April 6, 2018, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department sanctioned a number of Russian businessmen and companies, as well as Russian government officials and two state-owned entities. The...more

Kelley Drye & Warren LLP

Distributor danger: OFAC case highlights sanctions liability for bad acts by distributors and foreign subsidiaries

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Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But...more

Sheppard Mullin Richter & Hampton LLP

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

Kelley Drye & Warren LLP

The Paper Caper: U.S. Persons Cannot Help Foreign Subsidiaries Or Affiliates With Sanctioned Country Transactions

A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign...more

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