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
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more
If there is one issue that is repeated over and over (and over), it is third-party risks. Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world. And with this enforcement...more
In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against...more
The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....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
What a year for OFAC – Amazon settled its case for OFAC violations and now add Berkshire Hathaway. Lat year, Apple settled with OFAC for sanctions violations....more
OFAC is a steady enforcement agency. As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions. ...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
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more
In yet another enforcement action, OFAC announced a $1.709 million settlement with PACCAR, Inc., for 63 apparent violations of the Iran Sanctions Program by DAF Trucks, a wholly-owned subsidiary based in Eindhoven,...more
ANTICORRUPTION DEVELOPMENTS - Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference - On June 27,...more
There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more
The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank....more
OFAC is definitely off to a fast start this year – it recently announced its fourth enforcement action for 2019. So far, OFAC has collected over $7 million in civil penalties. ...more
ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime,...more
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more
ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more
Here is a real zinger – clients sometimes do not tell their lawyers the truth. I will wait a minute while you get off the floor because I know everyone is shocked and amazed that this happens. But in the recent ZTE case,...more