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Office of Foreign Assets Control (OFAC) Enforcement Actions Supply Chain

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

Foley & Lardner LLP on

Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...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

NAVEX

New Year, New Administrations, New Responses

NAVEX on

Global election results mean the coming years are going to be full of change for compliance. This article, from our 2025 Top 10 Trends in Risk & Compliance explores how you can prepare....more

The Volkov Law Group

Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV)

The Volkov Law Group on

Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime.  OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more

Husch Blackwell LLP

The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and...

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify...more

The Volkov Law Group

Episode 328 -- Sanctions Enforcement Risks and Redlines

The Volkov Law Group on

In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

The Volkov Law Group on

While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more

The Volkov Law Group

Distribution Chains and Sanctions Compliance (Part II of IV)

The Volkov Law Group on

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment.  Additionally, companies may maintain parallel sales activities in markets between their...more

The Volkov Law Group

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

The Volkov Law Group on

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

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

The Volkov Law Group

U.S. Commerce and Treasury Departments Increase Sanctions Against Chinese Entities

The Volkov Law Group on

The United States Department of Commerce and Department of Treasury continue to ramp up sanctions against Chinese entities as part of the ongoing tension between China and the United States. ...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Agencies Issue Business Advisory Warning of Xinjiang-Related Supply Chain Exposure and OFAC Imposes Blocking Sanctions on...

- On July 1, the Departments of Commerce, Homeland Security, State, and the Treasury issued a joint advisory on the “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Sanctions Compliance Guidance Released for the Global Maritime, Energy and Metals Sectors

- On May 14, 2020, OFAC, the Department of State and the U.S. Coast Guard jointly released guidance for persons involved in the maritime industry regarding common deceptive shipping practices used to subvert U.S. and United...more

Foley & Lardner LLP

Recent Government Announcements Confirm Importance of International Regulatory Compliance for Automotive Companies

Foley & Lardner LLP on

Over the last three years, the current administration has imposed the largest export controls penalty, the second-largest economic sanctions penalty, and four of the ten largest anti-bribery penalties of all time, signaling...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

Morrison & Foerster LLP

Top 10 Lessons Learned From OFAC’s 2019 Trade-Related Enforcement Actions (OFAC 2019 Year In Review, Part 3)

Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more

Kilpatrick

3 KEY TAKEAWAYS: OFAC’s 2019 Sanctions Enforcement

Kilpatrick on

2019 was a busy year for the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”): in May, OFAC provided a compliance roadmap in its “Framework for OFAC Compliance Commitments” guidance document (see our 6 Key...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Holland & Hart LLP

OFAC: Sanctions Compliance Provisions in Lease Agreements Alone May Be Insufficient

Holland & Hart LLP on

On November 7, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced in an Enforcement Information that Apollo Aviation Group, LLC (Apollo), a Florida-based commercial aviation...more

Society of Corporate Compliance and Ethics...

US reaches settlement with General Electric over alleged sanctions violations

Report on Supply Chain Compliance 2, no. 20 (Oct. 24, 2019) - The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with General Electric Company regarding transactions involving a...more

The Volkov Law Group

OFAC Fines US Company for Iran Sanctions Violations

The Volkov Law Group on

There is no question that OFAC continues to dominate the enforcement landscape this year.  OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more

The Volkov Law Group

OFAC Announces Two Sanctions Enforcement Settlements

The Volkov Law Group on

What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first...more

Bass, Berry & Sims PLC

OFAC Settles with Cosmetics Company, Reiterates Importance of Supply Chain Compliance

• Company committed multiple apparent violations of U.S. sanctions on North Korea • Penalty imposed in part because of company’s “non-existent” sanctions compliance program • Settlement underscores need to address supply...more

King & Spalding

e.l.f. Cosmetics Agrees to Pay Nearly $1 Million To Settle Apparent Violations Of U.S. Sanctions Against North Korea

King & Spalding on

This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence - On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - July 2018

ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more

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