News & Analysis as of

It’s Not Rocket Science: Taking the Steps Necessary to Avoid Costly Sanctions Violations

The $963 million settlement OFAC recently reached with French banking giant BNP Paribas SA (BNP) was both the largest OFAC settlement to date and represents only a small fraction of the nearly $9 billion in total fines...more

The United States Designates Seven Individuals Under Executive Order 13660 Relating to Separatist Activity in Ukraine

On June 20, 2014, the US Office of Foreign Assets Control (“OFAC”) issued further designations under Executive Order 13660 (“EO 13660”). EO 13660, which was signed on March 6, 2014, authorizes the United States to impose...more

FinCrimes Update - Volume 1, Issue 3

On May 8, OFAC released enforcement information regarding “apparent violations” of the Cuban Assets Control Regulations by Canadian subsidiaries of a U.S. insurance company. The U.S. company self-reported 3,560 apparent...more

Treasury Department Announces $21 Million Resolution Of Alleged Iran and Sudan Sanctions Violations

On June 5, the Treasury Department’s Office of Foreign Assets Controls (OFAC) announced a Dutch aerospace firm has agreed to pay $21 million to resolve allegations that the company violated U.S. sanctions on Iran and Sudan....more

Red Notice Newsleter

Welcome to the May 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month, on the anticorruption front, Avon Products, Inc. (“Avon”) agrees to pay USD $135 million to settle a...more

Practical Guidance for Dealing with OFAC’s Recently Released Ukraine Related Sanctions Regulations and the EU’s Ukraine Sanctions

On May 8, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued regulations to implement three Executive Orders issued by President Obama in March regarding the situation in Ukraine. The...more

Western Sanctions Expand as Tension in Ukraine Continues

The United States, Canada and the European Union have designated a number of additional officials and companies as the unrest continues in eastern Ukraine. The United States also imposed sanctions on the head of Russian...more

Insurance Company Resolves Apparent Cuba Sanctions Violations

On May 8, OFAC released enforcement information regarding “apparent violations” of the Cuban Assets Control Regulations by Canadian subsidiaries of a U.S. insurance company. The U.S. company self-reported 3,560 apparent...more

OFAC Publishes Initial Ukraine-Related Sanctions Regulations

On May 8, OFAC issued regulations to implement recent Executive Orders establishing sanctions against Russian individuals and entities related to the situation in Ukraine. The Ukraine-Related Sanctions Regulations, 31 C.F.R....more

Coping With Rapidly Expanding U.S. Sanctions On Russia

The U.S. Office of Foreign Assets Control (OFAC) issues the fourth round of designations blocking the assets of seven additional Russian individuals as well as 13 Russian companies, including several Russian banks....more

U.S. and EU impose further sanctions in relation to actions in Ukraine

This E-Alert provides an update on the U.S. and EU sanctions discussed in the Allen & Overy E-Alerts dated March 13, 2014, titled “United States and European Union authorize sanctions relating to situation in Ukraine”; March...more

U.S. Imposes Further Economic Sanctions on Russian Officials and Entities in Connection with the Crisis in Crimea

On April 28, 2014, the Office of Foreign Assets Control (OFAC) imposed a new round of Ukraine-related sanctions on more than two dozen Russian companies and government officials. The latest sanctions, supplementing previous...more

"An Update on Economic Sanctions Related to Events in Ukraine"

On April 25, 2014, following a meeting of the G7 in which member countries broadly agreed to take further action against Russia in response to political violence and unrest in Ukraine, U.S. officials imposed sanctions against...more

UPDATE: Developments in the Ukraine and Impact on Investments

Following the agreement between G7 leaders on 25 April to promptly impose additional sanctions on Russia as it has failed to deliver on its Geneva commitments, the EU and the U.S. have now added new individuals and entities...more

Latest Round of US and EU sanctions on Russia and the Russian Government Reaction

In response to recent events in Ukraine, the United States and European Union imposed yet another round of sanctions this week. In response, Russia is considering a number of countermeasures that may affect U.S. and EU...more

The United States Designates Seven Russian Individuals and Seventeen Companies under Executive Order 13661, Imposes Additional...

Further Sanctions Designations: On April 28, 2014, the US Office of Foreign Assets Control (“OFAC”) issued further designations under Executive Order 13661 (“EO 13661”). EO 13661, which was signed on March 16, 2014,...more

OFAC Announces $6 Million Settlement To Resolve Alleged Cuba Sanctions Violations

On April 18, OFAC announced that a privately held travel services provider based in the Netherlands but majority-owned by U.S. persons agreed to pay nearly $6 million to resolve allegations that over a roughly six-year period...more

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

Sifting Through The Ukraine Economic Sanctions

It is odd how a foreign crisis can have a dramatic impact on the world of ethics and compliance. Foreign policy headaches turn into compliance nightmares when the United States becomes embroiled in foreign events....more

AML Enforcement And Sanctions

AML enforcement often includes sanctions violations. The Office of Foreign Asset Control (OFAC) is responsible for regulating and enforcing the sanctions regime....more

Implications of U.S. Sanctions Program on Intellectual Property Owners

To advance U.S. foreign policy and national security objectives, the U.S. maintains laws and regulations that impose economic sanctions against certain countries, individuals, and entities (the "U.S. Sanctions Program"). 31...more

Sanctions Round-Up: First Quarter 2014

In this edition: - Implementation of the Joint Plan of Action with Iran - Additional US Iran-Related Sanctions and Licenses - OFAC Civil Settlements - US and EU Sanctions in Response to the Situation in...more

New Item for Diligence Review Process: OFAC’s Foreign Sanctions Evaders List

On February 6, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published notice that it was listing 11 named parties as “Foreign Sanctions Evaders,” pursuant to Executive Order 13608 (May 1, 2012)...more

Complying with Economic Sanctions Is Critical to Businesses

Sanctions have recently been a favorite tool of U.S. foreign policy makers seeking to financially coerce compliance with their national security and foreign policy goals. Accordingly, the U.S. Treasury Department's Office of...more

French Bank Sets Aside Over $1 Billion for US Sanctions Violations

French bank BNP Paribas (BNP) recently announced it has set aside $1.1 billion to cover the anticipated cost of violations of US economic sanctions and anti-money laundering rules. The bank's own internal investigation...more

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