News & Analysis as of

Sanction Violations

Hogan Lovells

UK makes trade sanctions violation a strict liability offence and amends the legal advisory services ban

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Significant legislative changes have been made to the UK’s sanctions regime in the first half of September 2024, namely: These new amendments demonstrate the UK’s further efforts in imposing penalties against sanctions...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Society of Corporate Compliance and Ethics...

Is your reporting system worth $1 million?

Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more

Blank Rome LLP

OFAC Guidance on Extending the Statute of Limitations for Sanctions Violations Signals Aggressive Enforcement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) last week issued guidance regarding the extension of the statute of limitations for sanctions violations. This guidance follows the enactment of...more

Faegre Drinker Biddle & Reath LLP

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

Hogan Lovells

OFAC issues statute of limitations guidance for US sanctions violations and recordkeeping

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The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more

Katten Muchin Rosenman LLP

OFAC Announces Forthcoming Expanded Recordkeeping Rule

On July 22, 2024, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued a Guidance on Extension of Statute of Limitations (the "Guidance"). The Guidance calls attention to the recently...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

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The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

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On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Ankura

Navigating OFAC Sanctions Risks in the Digital Realm: IP Addresses and Effective Controls

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In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more

McGuireWoods LLP

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

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On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...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

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

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On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more

The Volkov Law Group

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

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We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have...more

The Volkov Law Group

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

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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

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

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

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

The Volkov Law Group

Episode 324 -- Third-Party Risks and Sanctions Compliance

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With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...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

BCLP

Adoption of Directive (Ue) 2024/1226 on Criminalisation of Violations of EU Sanctions: What Are the Stakes Involved in Transposing...

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On 19 May, Directive (EU) 2024/1226 on the definition of criminal offences and sanctions for breaches of EU restrictive measures, adopted by the EU Council on 24 April, entered into force. By harmonizing the laws of the...more

White & Case LLP

Practical and legal implications in France following the EU harmonization of enforcement and penalties for sanctions violations

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On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more

White & Case LLP

Practical and legal implications in Germany following the EU harmonization of enforcement and penalties for sanctions violations

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On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more

White & Case LLP

Practical and legal implications in Poland following the EU harmonization of enforcement and penalties for sanctions violations

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On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more

White & Case LLP

Practical and legal implications in Spain following the EU harmonization of enforcement and penalties for sanctions violations

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On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more

Latham & Watkins LLP

Sanctions Update: EU Takes Step to Harmonise Criminal Penalties for Breaches of EU Sanctions

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The new Directive (EU) 2024/1226 defines criminal offences and penalties for breaches of EU sanctions. This Client Alert summarises key provisions and implications for businesses. This Client Alert is published in the...more

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