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Office of Foreign Assets Control (OFAC) Corruption Enforcement Actions

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

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Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

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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

The Volkov Law Group

OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions

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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

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

The Volkov Law Group

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

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OFAC is getting ready for a big year.  While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive...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

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

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There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

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As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

The Volkov Law Group

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

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On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

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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

The Volkov Law Group

Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II)

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Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations....more

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more

The Volkov Law Group

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

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Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

The Volkov Law Group

OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

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The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus...more

The Volkov Law Group

OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions

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Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front.  Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

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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

The Volkov Law Group

Newmont Corporation and Chisu International Settle with OFAC to Resolve Violations of Cuban Sanctions Program

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Even while the Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been properly focused on implementing and enforcing the Russia sanctions scheme in response to Russia’s unprovoked invasion of Ukraine, OFAC...more

Torres Trade Law, PLLC

OFAC Sends Clear Message to Parties Conducting Business with Entities on OFAC’s Sectoral Sanctions Identification List

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As the U.S. and the European Union continue to impose new sanctions on Russia in response to the invasion of Ukraine, regulatory authorities continue their pursuit of companies and individuals who violate those sanctions. The...more

The Volkov Law Group

Appellate Court Upholds OFAC Designation of Oleg Deripaska, a Major Oligarch

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The Office of Foreign Asset Control’s designation of an entity as a Specially Designated National (SDN) is the “kiss of death.”  Such designation not only has a direct impact on an SDN’s ability to engage in business but has...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

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Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

The Volkov Law Group

2022 OFAC and Sanctions Enforcement Predictions

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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment.  Since the pandemic, OFAC has maintained a strong profile, while managing a difficult...more

The Volkov Law Group

OFAC Closes Out Year with Two-Fisted Settlement with TD Bank

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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

The Volkov Law Group

Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve

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Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more

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