News & Analysis as of

Office of Foreign Assets Control (OFAC) Sanction Violations Enforcement

Bass, Berry & Sims PLC

German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran

Bass, Berry & Sims PLC on

Key Points: - Long-arm of U.S. sanctions jurisdiction reaches conduct by European company. - Violation involved shipment to Iran from Australia, a close U.S. ally. On December 3, the Treasury Department’s Office of...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Snell & Wilmer

United States Government Doubles Statute of Limitations for Sanctions Violations

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Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Sheppard Mullin Richter & Hampton LLP

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

Adams & Reese

International Compliance Digest – April 2024

Adams & Reese on

April was another month of robust trade actions aimed at foreign goods, export compliance, and heightened enforcement powers. DHS issued an enhanced strategy policy on the textile industry with a focus on de minimis...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

Bass, Berry & Sims PLC on

December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

Proskauer - Blockchain and the Law

Don’t Get Caught Up in the Mix: OFAC Sanctions Another Crypto Mixer for Potential Violations of Sanctions Regulations and FinCEN...

U.S. government agencies continue to take action against cryptocurrency mixing services that enable cybercriminals to obfuscate the trail of stolen proceeds on public blockchains stemming from illicit cyber activity. On...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

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