News & Analysis as of

Office of Foreign Assets Control (OFAC) Penalties

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Snell & Wilmer

The Uncertain World: Nearshoring, Economic Development, and the Next Frontier

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Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (October 25, 2023)

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A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more

Dunlap Bennett & Ludwig PLLC

Navigating Restricted Parties Lists in the United States: Screening to Facilitate Compliance

Under the U.S. Export Administration Regulations (EAR), Part 736 General Prohibition #5 (EAR 736.5) imposes restrictions on certain activities related to exports, reexports, and transfers (in-country) of items subject to the...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

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

Snell & Wilmer

Russia’s Purported Annexation of Ukraine Prompts Expanded Sanctions for Individuals and Entities in Third Countries Supporting...

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On September 30, 2022, the United States instituted new sanctions to address the ongoing Russian-Ukraine conflict. The new sanctions follow the Leaders of the Group of Seven’s (“G7”) statement condemning Russia’s referendum...more

Harris Beach PLLC

Cryptocurrency: In the Face of Increased Enforcement, Be Prepared

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This summer was a busy one for cryptocurrency regulators, with aggressive actions potentially signaling an increase in consumer protection compliance activity. In August alone, the New York Department of Financial Services...more

Bracewell LLP

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

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In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

Sheppard Mullin Richter & Hampton LLP

Do You Have a Risk-Based Sanctions Compliance Program?: In the Event of a Ransomware Attack, OFAC Wants to Know

In the wake of increased ransomware attacks over the course of the last several months, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has updated a guidance it released last year on potential...more

K2 Integrity

OFAC Releases Updated Ransomware Advisory and Announces First Designation of Cryptocurrency Exchange

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On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Arnall Golden Gregory LLP

Compliance News Flash - December 2020 #2

Arnall Golden Gregory LLP is pleased to provide you with the Compliance News Flash, which includes current news briefs relevant to background screening, immigration and data privacy, for the benefit and interest of our...more

Saul Ewing LLP

Paying or Facilitating Payment of Ransomware Demands May Result in Criminal and Civil Penalties From OFAC

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Companies that make or facilitate ransomware payments were given a strong reminder of their due-diligence and compliance obligations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). ...more

Society of Corporate Compliance and Ethics...

Focus on US economic sanctions compliance: OFAC imposes fines and expects more monitoring

Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more

Husch Blackwell LLP

Increased OFAC Penalties For Companies Lacking Sanctions Compliance Programs

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Key Points- Members of the international business community who are subject to U.S. trade sanctions and who have non-existent or inadequate sanction compliance programs (SCPs) are now potentially subject to significantly...more

Dechert LLP

OFAC Imposes First Penalty for Russia Sectoral Sanctions Violations

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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

Bass, Berry & Sims PLC

OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening

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• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine • Violations identified during pre-acquisition due diligence on contractor • Denied persons screening was conducted but missed prohibited...more

Akin Gump Strauss Hauer & Feld LLP

The Export Control Reform Act and Possible New Controls on Emerging and Foundational Technologies

• ECRA became law on August 13, 2018. It is the permanent statutory authority for the EAR, which is administered by the U.S. Department of Commerce’s BIS. The new law codifies long-standing BIS policies and does not require...more

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