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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no...more
On October 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published a Maritime Oil Industry Advisory (“Advisory”)—together with the so-called Price Cap Coalition (“Coalition”), consisting...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more
Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million. Murad was acquired by Unilever United...more
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more
On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”),...more
In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former...more
Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program. Alliance Steel is a designer and manufacturer of prefabricated steel structures....more
On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more
On July 8, the U.S. Department of the Treasury announced a settlement with Amazon.com, Inc., related to the company's potential civil liability for apparent violations of multiple sanctions programs resulting from...more
On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions...more