2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions — Eagle Shipping and Park Strategies....more
OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more
On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more
With the increasing criticism of DOJ’s use of deferred prosecution agreements (“DPAs”), it was inevitable that the courts would assert themselves in this area....more
We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more