Office of Foreign Assets Control

News & Analysis as of

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

Real OFAC Policy Changes Toward Iran—OFAC will consider non Ag/Med exports

As a new round of nuclear talks involving American, European, and Iranian leaders commence this week in Vienna it appears that the first-step deal agreed upon in January has already led to significant changes in OFAC’ s...more

Governance & Securities Law Focus: Europe Edition, April 2014

In this issue: - EU Developments - German Developments - UK Developments - Us Developments - Excerpt from EU Developments - European Commission Proposes to Introduce Shareholder "Say...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

OFAC Issues General License G Regarding Certain Academic Exchanges and Educational Services in Iran

On March 19, 2014, the Office of Foreign Assets Control (OFAC) issued General License G pertaining to certain academic exchanges and the exportation or importation of certain educational services to Iran. The General License...more

A Vital Link to Any International Trade Compliance Program: The Human Resource Manager

Governments in every country are taking international trade compliance seriously. Unlike other company departments that heavily rely on automation to track supply chain compliance, those departments responsible for...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

Red Notice Newsletter - March 2014

This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...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

$1.1 Billion and Counting – The New Era of OFAC Enforcement

On February 13, 2014, BNP Paribas ("BNP"), France's largest bank, announced in its fourth quarter results that it will soon be joining the growing community of banking institutions that, within the past five years, have been...more

OFAC Expands and Clarifies License for Exports of Personal Communications Items and Services to Iran

The Department of the Treasury, Office of Foreign Assets Control (OFAC), amended the Iran personal communications General License D-1 (GL D-1) on Feb. 7, 2014, expanding, clarifying and superseding the May 2013 General...more

OFAC Publishes New Guidance On Temporary And Limited U.S. Sanctions Relief For Iran

On January 30, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action...more

One More List: 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 eleven named parties as “Foreign Sanctions Evaders,” pursuant to Executive Order 13608 (May 1,...more

OFAC Issues New Foreign Sanctions Evaders List

The Office of Foreign Assets Control (“OFAC”), of the U.S. Department of the Treasury, has created a new list – the Foreign Sanctions Evaders List (“FSE List”) – that U.S. companies and others should consult when engaging in...more

BVI Company In Trouble Over Plans to Ship Engines to Iran

We usually don’t post enforcement summaries. However, I wanted to insure everyone was aware that the United States government is really going after non-U.S. entities. Please see below. Note it is the Commerce Department not...more

Capital Thinking: International

Executive and Legislative Branch Activity - Iran - On February 6, Treasury’s Office of Foreign Assets Control introduced the Foreign Sanctions Evaders List (FSE List) to identify foreign persons sanctioned under...more

Temporary Iran Sanctions Relief

Relief is very limited and alleviates threat of sanctions regarding transactions by non-U.S. or foreign persons. On January 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published...more

Temporary Suspension of Limited US Sanctions Restrictions on Dealings With Iran

On January 20, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued Guidance Relating to the Provision of Certain Temporary Sanctions Relief (Guidance) to explain the limited and temporary...more

OFAC Announces Sanctions Settlement With Securities Intermediary

On January 23, the Treasury Department’s OFAC announced that a Luxembourg bank agreed to pay $152 million to resolve potential civil claims that the bank concealed the interest of the Central Bank of Iran (CBI) in certain...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

"'Know Your Customer': OFAC Raises Due Diligence Expectations of Non-US Banks"

Since 2005, a series of very large non-U.S. banks — including ABN AMRO, Credit Suisse and ING — have paid significant penalties to U.S. authorities for processing funds transfers through the United States related to business...more

"OFAC and German Foreign Trade Regulations: Underwriters Attempt to Square the Circle"

When negotiating underwriting and purchase agreements for securities offerings by German issuers, legal advisers face conflicting requirements under U.S. economic sanctions laws administered by the Office of Foreign Assets...more

United States Implements Temporary Changes to Iran Sanctions under Interim Agreement

On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more

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