You are reading the June 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. - June saw...more
On June 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14098, against four companies for generating revenue from, and contributing to, the conflict...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more
In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”),...more
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
On September 17, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) reached a $894,111 settlement with Comtech Telecommunications Corp. (“Comtech”) and its subsidiary Comtech EF Data Corp. (“EF...more
Comtech Telecommunications (“Comtech”) and Comtech EF Data Corp. (“EF Data”) agreed to pay OFAC $894,111 for violations of the Sudan Sanctions Program. ...more
In the previous articles in our series Engine Leasing, the Fundamentals, BCLP’s global aviation team has discussed the attraction of engine leasing and the key economic drivers. It has discussed the legal risks associated...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention - The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the sanctions laws and related sanctions programs of the United States. As a key...more
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
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
On October 11, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on Ashraf Seed Ahmed Hussein Ali, a Sudanese national widely known by his pseudonym “Al-Cardinal,” pursuant...more
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
Institutional investors, asset managers and others in the financial services industry increasingly are adopting environmental, social and governance (“ESG”) investment principles to attract and retain business from socially...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
• Ericsson Caused Violation by Having U.S. Party Ship Equipment to Sudan • U.S. Employee Facilitated Sudan Business • OFAC Expects Parties Conducting International Business to Have Robust Compliance Processes In June...more
I will admit it – I changed this posting from its original draft. I intended to write about the absence of any OFAC enforcement actions for 2018. I went to double-check the OFAC enforcement website, and lo and behold, OFAC...more
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more
The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more
Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more