News & Analysis as of

Office of Foreign Assets Control (OFAC) Failure to Comply

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

The Volkov Law Group

OFAC Settles First Case in 2023: Godfrey Phillips India Pays $332,500 for Violations of North Korea Sanctions Program

The Volkov Law Group on

OFAC had a quiet start to the year – no enforcement actions but plenty of new and revised sanctions against Russia.  OFAC started off March 2023 with a new enforcement action against Godfrey Phillips India, a tobacco...more

The Volkov Law Group

OFAC Enforcement Action: Double Check Your Screening Tools

The Volkov Law Group on

Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC...more

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

The Volkov Law Group on

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

OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program

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OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more

The Volkov Law Group

Trade Compliance Dominates Enforcement Landscape (Part I of IV)

The Volkov Law Group on

Well, we are still waiting for the “big” FCPA enforcement actions.  Do not get me wrong – they are coming.  My suspicion is that they are being held up and calculated with a splash to announce the results of the White House’s...more

The Volkov Law Group

Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program

The Volkov Law Group on

Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program.  Alliance Steel is a designer and manufacturer of prefabricated steel structures....more

The Volkov Law Group

UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program

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UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions...more

The Volkov Law Group

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

The Volkov Law Group on

When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks....more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

The Volkov Law Group on

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

The Volkov Law Group

OFAC Issues First Two Enforcement Actions of 2020

The Volkov Law Group on

OFAC had a big year in 2019 and 2020 looks like a continuation.  In the last week, OFAC issued two enforcement actions —  Eagle Shipping and Park Strategies....more

The Volkov Law Group

OFAC Loses Exxon Sanctions Enforcement Case

The Volkov Law Group on

In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia...more

The Volkov Law Group

Apollo Aviation Group Pays $210k to OFAC for Violations of Sudanese Sanctions Program

The Volkov Law Group on

Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program.  Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more

The Volkov Law Group

General Electric Pays OFAC $2.7 Million for Violations of Cuba Sanctions Program

The Volkov Law Group on

OFAC’s aggressive enforcement program continues to bear fruit.  The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program. So...more

The Volkov Law Group

OFAC Announces $1.7 Million Settlement with Truck Manufacturer for Violations of Iran Sanctions Program

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In yet another enforcement action, OFAC announced a $1.709 million settlement with PACCAR, Inc., for 63 apparent violations of the Iran Sanctions Program by DAF Trucks, a wholly-owned subsidiary based in Eindhoven,...more

Hogan Lovells

U.S. Sanctions regulator outlines expectations for Global Sanctions Compliance: impact on Private Equity

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On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more

Hogan Lovells

OFAC Issues Press Release for a Finding of Violation Against State Street Bank and Trust Co. Where No Penalty was Assessed

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OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more

The Volkov Law Group

DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to...

The Volkov Law Group on

The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more

The Volkov Law Group

Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III)

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Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank....more

The Volkov Law Group

OFAC Announces Two Sanctions Enforcement Settlements

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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

Ballard Spahr LLP

Practical Tips in Action: The Mashreqbank AML Enforcement Action

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NYDFS Action Highlights the Need for Good Monitoring – and Good Consultants - In part one of this two-part post, we provided some practical tips for financial institutions to increase the chances that their Anti-Money...more

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