The First Bank of Romania and JC Flowers agreed to pay OFAC $862,318 to settle violations of Iran and Syria Sanctions Programs. First Bank is owned by its U.S. parent, JC Flowers & Company. ...more
Hong Kong Updates and Alerts - New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended - On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...more
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. ...more
On May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury and the U.S. Coast Guard jointly released a long-awaited “Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related...more
On May 14, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the U.S. Coast Guard issued a Sanctions Advisory for the Maritime Industry, Energy and Metals...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
The new Iran sanctions imposed by the Trump Administration are not the only recent sanctions actions of note. Congress has also shown its willingness to use sanctions as a foreign policy tool, with certain sanctions...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
Report on Supply Chain Compliance Volume 2, Number 20. (October 24, 2019) - Following statements from U.S. President Trump that led to the withdrawal of U.S. support from former Kurdish allies in northern Syria, Turkish...more
In light of Turkey’s military intervention in northeast Syria, President Donald Trump issued, on October 14, 2019, Executive Order 13894 (EO 13894), “Blocking Property and Suspending Entry of Certain Persons Contributing to...more
On March 25, 2019, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), along with the U.S. Department of State and the U.S. Coast Guard, issued an updated version of a similar advisory issued on...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
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
On August 2, 2017, President Donald Trump signed into law the Countering America’s Adversaries Through Sanctions Act (the Act), which significantly expands U.S. sanctions against Russia while enacting modest new sanctions on...more
On Tuesday, July 18, 2017, the Trump administration announced new sanctions against entities and individuals with ties to Iran. The U.S. Department of State (DOS) and U.S. Department of the Treasury have listed 18 entities...more
While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more
Throughout the eight years of the Obama administration, the development and implementation of economic sanctions was a key element of U.S. foreign and national security policy. This strategy continued into the post-election...more
OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more
Below is a summary of developments since our previous update in March relating to European Union (“EU”) sanctions on Iran, North Korea and other jurisdictions as well as highlights of recent changes with respect to the...more
The U.S. Department of State imposed sanctions on September 2, 2015, against 23 companies around the world for involvement in the transfer or purchase to or from Iran, North Korea or Syria of goods, services or technology...more