Corruption, Crime & Compliance: Deep Dive into SCG Plastics’ $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program
Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program
The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Compliance into the Weeds - SAP Trade Sanctions Enforcement Action
Corporate Law Report: Managing Cyber Risks, BYOD, Obama's NLRB Crisis, Iran Sanctions, and More
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more
On February 27, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Iran Final Rule”) imposing new export control measures against Iran caused by to its support of Russian...more
The U.S. government recently has taken several actions targeting Iran and Iranian entities for contributing to Russia’s military and defense industrial base to address Russia’s use of Iranian unmanned aerial vehicles (UAVs)...more
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
The long political and prosecution standoff between the U.S. Government/Department of Justice and Huawei/China ended abruptly last week when Wanzhou Meng, CFO of Huawei Technologies Co., Ltd. appeared in federal district...more
On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more
Sales of your software are robust around the globe. You have a network of third-party resellers, distributors or implementation partners that are driving international growth. Your customers praise your efficient maintenance...more
The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more
In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more
The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions. As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is...more
The Justice Department recently announced a settlement with Avnet Asia for illegal shipments of sensitive U.S. commodities to China and Iran. Under the settlement, DOJ agreed to a non-prosecution agreement (NPA) in exchange...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
When you are hot, you are hot. (And when you are not, you are not; Thank you Jerry Reed, Country Singer). OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks....more
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. ...more
Third-country companies doing business with Iran’s construction, mining, manufacturing, or textiles sectors are now at increased risk of being sanctioned. On Friday, January 10, President Trump issued Executive Order (EO)...more
FOURTH QUARTER 2019 - - Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies. - In the wake of...more
Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more
On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more
A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more
On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more
On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a number of changes to the Iranian Transactions and Sanctions Regulations (“ITSR,” 31 C.F.R. Part 560) that expanded the...more