News & Analysis as of

Office of Foreign Assets Control (OFAC) Due Diligence Penalties

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...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

Bass, Berry & Sims PLC

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

Bass, Berry & Sims PLC on

• 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

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

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