FINCast Ep. 19 - The DPRK Sanctions Program
On March 21, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) officially lifted sanctions on Tornado Cash, the decentralized cryptocurrency mixer it had blacklisted in August 2022....more
On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens. This attack marked a new pinnacle in the...more
Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more
On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more
The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...more
North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more
On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more
OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more
During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more
On May 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order (E.O.) 13687 and E.O. 13810, against four entities and one individual, involved in obscure...more
The Justice Department warned companies that sanctions enforcement is the “new FCPA.” DOJ just delivered its first salvo to back up its message....more
On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement with one of the world’s largest tobacco companies to resolve potential civil liabilities stemming from...more
OFAC had a quiet start to the year – no enforcement actions but plenty of new and revised sanctions against Russia. OFAC started off March 2023 with a new enforcement action against Godfrey Phillips India, a tobacco...more
On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $332,500 settlement with an India-registered tobacco company to resolve allegations that it “requested payment in U.S. dollars for...more
On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against three entities and two individuals for their roles in illicitly generating revenue to support the government of...more
In today’s rapidly changing sanctions landscape, a bare minimum approach to sanctions compliance can leave organizations open to a range of risks that can wreak havoc across their business. Holistic approaches to due...more
Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more
An inherent aspect of any new technology is that it doesn’t take long for bad actors to figure out how it can be weaponized for nefarious purposes. Cyber-related technologies represent an increasingly dangerous area of risk...more
With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in...more
The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
ACI’s Annual Flagship Conference on Economic Sanctions Enforcement and Compliance is widely regarded as the premier conference designed for those working in global sanctions compliance, internal audits and investigations,...more
Last week, the House Permanent Select Committee on Intelligence (HPSCI) and the Senate Select Committee on Intelligence (SSCI) each held a hearing on the US Intelligence Community’s (IC) 2022 Annual Threat Assessment, a...more
On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more
The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program. At the end of the year, OFAC announced a settlement with TD Bank...more