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International Trade Enforcement Roundup – February 2024 Update

February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

International Trade Enforcement Roundup – December 2023 Update

December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

International Trade Enforcement Roundup – November 2023 Update

You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your...more

International Trade Enforcement Roundup – July 2023 Update

July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

International Trade Enforcement Roundup – March 2023

You are reading the March 2023 edition of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. March saw...more

Russia, Ukraine: Update as of June 1

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more

Sanctions Enforcement Update: Penalties for Logistics, Telecom Companies

• Actions underscore long arm of U.S. sanctions jurisdiction • Voluntary disclosures and cooperation can lead to significant penalty reductions • Facilitation of a violation is treated the same as a direct...more

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

• $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

OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening

• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine • Violations identified during pre-acquisition due diligence on contractor • Denied persons screening was conducted but missed prohibited...more

Swedish Telecom Company Pays Penalty for Sanctions Violation

• Ericsson Caused Violation by Having U.S. Party Ship Equipment to Sudan • U.S. Employee Facilitated Sudan Business • OFAC Expects Parties Conducting International Business to Have Robust Compliance Processes In June...more

US Hammers ZTE with Export Denial Order, May Further Weaken Trade with China

• 7-year denial order imposed against Chinese telecommunications equipment maker • Denial order strictly limits business with company • Action comes as U.S. imposes other trade restrictions on China On April 16, U.S....more

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

U.S. Penalizes Exxon for Violating U.S. Sanctions on Russia, May Have Complicated How U.S. Companies Do Business in Russia

On July 20, 2017, the U.S. Treasury Department Office of Foreign Assets Control (OFAC) announced that ExxonMobil (Exxon) must pay a $2 million penalty for violating U.S. sanctions on Russia.  On the same day, Exxon responded...more

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

The Long Arm of U.S. Sanctions: Penalty Imposed Against Canadian Subsidiary of U.S. Subsidiary of Japanese Company

On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the...more

Lessons from the Historic ZTE Enforcement Action

On March 7, 2017, Chinese telecommunications company, Zhongxing Telecommunications Equipment Corp. (ZTE), signed on to three separate settlement agreements with the United States, agreeing to pay $892 million for violations...more

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

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