Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
FCPA Compliance and Ethics Report-Episode 142-Reflections on the Goodyear FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action
Cross-Border Update on Investing and Doing Business in the United States
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
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
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
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
- 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
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
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