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Sanction Violations

Michael Volkov

OFAC Ends 2020 with Two Enforcement Actions

Michael Volkov on

OFAC reported two new enforcement actions in the week between Christmas and New Year’s.  The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital...more

Buchalter

Congress Makes Sweeping Changes to Money Laundering Enforcement

Buchalter on

On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...more

Lowenstein Sandler LLP

Compliance Matters: What Executives Should Know About International Shipments

Lowenstein Sandler LLP on

As trade compliance gains more traction, US regulators have made it clear that having compliance policies in place is critical, regardless of the company size or the industry. The implementation of such compliance programs...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Releases Advisory on Sanctions Risk Involving Ransomware Payments

In early October, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory, warning of the potential risk of sanctions to companies and individuals who pay ransomware payments. The...more

Spilman Thomas & Battle, PLLC

Decoded: Technology Law Insights - Issue 8, October 2020

Attorney General William P. Barr Announces Publication of Cryptocurrency Enforcement Framework - "The Framework provides a comprehensive overview of the emerging threats and enforcement challenges associated with the...more

Weiner Brodsky Kider PC

Paying Ransomware Demands Can Create Risk of Violating OFAC Sanctions

Weiner Brodsky Kider PC on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new guidance regarding how paying ransoms due to ransomware attacks can potentially violate OFAC sanctions....more

White & Case LLP

US Treasury Advises on Potential Sanctions Risks Raised by Ransomware Attacks

White & Case LLP on

On October 1, 2020, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued an advisory opinion on the sanctions risks associated with certain cyberattacks ("OFAC Guidance"). The OFAC Guidance...more

Michael Volkov

OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions

Michael Volkov on

OFAC continues to chalk up enforcement actions.  For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties....more

Hogan Lovells

OFAC settles case involving goods with more than de minimis controlled U.S.-origin content

Hogan Lovells on

On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more

Robinson+Cole Data Privacy + Security Insider

OFAC Issues Advisory on Sanctions for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory “to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more

Kilpatrick Townsend & Stockton LLP

4 Key Takeaways - OFAC Enforcement Actions From June to September 2020

From June through mid-September of 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published six settlements of apparent sanctions violations (Check out our previous Four Key Takeaways...more

Michael Volkov

Comtech Telecomm Settles OFAC Violations for $894,111

Michael Volkov on

Comtech Telecommunications (“Comtech”) and Comtech EF Data Corp. (“EF Data”) agreed to pay OFAC $894,111 for violations of the Sudan Sanctions Program. ...more

Michael Volkov

Deutsche Bank Settles Two OFAC Cases Totaling $583K for Violations of Ukraine-Russia Sanctions

Michael Volkov on

Deutsche Bank continues to have its problems – legal, compliance and reputational.  Now, we can add OFAC sanctions compliance to the list of Deutsche Bank’s troubles....more

Hudson Cook, LLP

Deficiencies in Sanctions Screening Process Lead to Settlement

Hudson Cook, LLP on

On July 8, the U.S. Department of the Treasury announced a settlement with Amazon.com, Inc., related to the company's potential civil liability for apparent violations of multiple sanctions programs resulting from...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Michael Volkov

Apple and Amazon Fall to OFAC Enforcement for “Screening Errors” (Part III of III)

Michael Volkov on

It is hard to argue that Apple and Amazon do not have the resources to implement state-of-the-art OFAC compliance programs. After all, the two largest companies in the world should stand as beacons of compliance with the full...more

Michael Volkov

OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III)

Michael Volkov on

In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will...more

K&L Gates LLP

Voluntary Disclosure: Newsflash August 2020

K&L Gates LLP on

A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more

Thomson Reuters Regulatory Intelligence and...

Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia

Regularly topping annual lists of the most transparent and least corrupt countries in the world, the Scandinavian nations of Norway, Sweden and Denmark have enjoyed a reputation for honesty, trust and fairness. When reports...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

Society of Corporate Compliance and Ethics...

US charges two Iranian nationals with sanctions violations

Report on Supply Chain Compliance 3, no. 10 (May 14, 2020) - The U.S. government charged two men with conspiring to launder money into the United States in order to purchase a Greek-owned ship to transport petroleum out...more

Kilpatrick Townsend & Stockton LLP

4 Key Takeaways - Office of Foreign Assets Control (OFAC) Sanctions Enforcement to Date in 2020

Through May of 2020, OFAC has published four settlements of apparent sanctions violations and one finding of violation. OFAC’s enforcement actions highlight four important and ongoing concerns related to the importance of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Commerce Department’s New Export-Related Restrictions Inhibit Semiconductor Design by and Manufacturing for Huawei

In response to the announcement on Friday by the U.S. Department of Commerce of new export-related restrictions targeting Huawei Technologies Co., Ltd. and several of its non-U.S. affiliates (collectively, Huawei), Sen. Ben...more

Thompson Coburn LLP

U.S. Releases guidance addressing sanctions evasion practices in maritime, energy and metal trading sectors

Thompson Coburn LLP on

On May 14, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Coast Guard issued a sanctions advisory for the maritime industry, the energy and metals...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - April 2020

ANTICORRUPTION DEVELOPMENTS - New Guilty Plea in College Admissions Scandal - On April 21, 2020, Jorge Salcedo, a former tennis coach at a prominent California university, entered into a plea agreement related to his...more

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