News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions Foreign Subsidiaries

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

K2 Integrity

SPACs and Sanctions: Due Diligence Considerations

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Economic sanctions have been increasingly used by countries and international organizations as a tool of foreign policy and national security. This increase in the use of sanctions, particularly by the U.S. Department of the...more

Kelley Drye & Warren LLP

Takeaways from OFAC’s $4.1 Million Settlement with Berkshire Hathaway

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This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. involving apparent violations of the U.S. embargo on Iran by a subsidiary in Turkey. Under the agreement,...more

Society of Corporate Compliance and Ethics...

[Webinar] Complying with U.S. Trade Sanctions: What every U.S. Company Needs to Know to Avoid OFAC’s Wrath - October 8th, 12:00 pm...

Learning objectives: - Overview of US sanctions regimes - To whom US laws apply (e.g. includes foreign subsidiaries; secondary sanctions) - key developments - compliance obligations and elements of an effective sanctions...more

Foodman CPAs & Advisors

Deficiencies or Weaknesses in an OFAC Sanctions Compliance Program can lead to OFAC Administrative Actions

On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”.  The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

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On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

WilmerHale

OFAC Crystallizes Expectations for Sanctions Compliance

WilmerHale on

On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

Williams Mullen

Company Incurs $7,772,102 Penalty for Dealing With Specially Designated National

Williams Mullen on

A U.S. company was recently charged with major sanctions violations when its foreign subsidiary entered business transactions with a party listed on the Specially Designated Nationals List. This is a reminder of the...more

The Volkov Law Group

OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions

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The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). ...more

Holland & Knight LLP

How Will the United States’ Withdrawal From the Iran Nuclear Accord Affect the Aviation Industry?

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On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more

Akin Gump Strauss Hauer & Feld LLP

New Sanctions on Russian Businessmen: Impact on Investment Funds

On April 6, 2018, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department sanctioned a number of Russian businessmen and companies, as well as Russian government officials and two state-owned entities. The...more

Kelley Drye & Warren LLP

Distributor danger: OFAC case highlights sanctions liability for bad acts by distributors and foreign subsidiaries

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Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But...more

Kelley Drye & Warren LLP

The Paper Caper: U.S. Persons Cannot Help Foreign Subsidiaries Or Affiliates With Sanctioned Country Transactions

A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign...more

Bass, Berry & Sims PLC

The Long Arm of U.S. Sanctions: Penalty Imposed Against Canadian Subsidiary of U.S. Subsidiary of Japanese Company

Bass, Berry & Sims PLC on

On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the...more

Bass, Berry & Sims PLC

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

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- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

The Volkov Law Group

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

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With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more

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