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Enforcement

Articles

Six Compliance Lessons for Non-Banks from Recent OFAC Enforcement Actions

April 20, 2020
By: Jack Walsh, Reporter, ACSS

Recently, the Office of Foreign Assets Control, or OFAC, has heightened its focus on industries outside the financial sector. The vast majority, over 70 percent of enforcement actions announced by OFAC in 2018 and 2019 targeted non-financial institutions. This trend continues into 2020 with the agency’s three enforcement actions to date targeting a lobbying firm, a maritime shipping company and a service provider for the civilian air transportation industry. (more…)

A Tough Cop in a Bad Neighborhood: Singapore’s Sanctions Regimes, Regulatory Authorities, and Areas of Concern for International Business

March 2, 2020
By: Jack Walsh, Content Writer, ACSS

From a regulatory perspective, Singapore is an intriguing case study.  On the one hand, the country is a financial and transportation hub for a region that is rife with transnational security threats. It serves as a major commercial nexus for business originating in countries under heavy international sanctions, including Iran and North Korea.  Shipping firms, trading houses, and financial intermediaries based in Singapore have long been key conduits of sanctions-busting schemes.

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OFSI’s New Teeth: Sanctions in the Wake of ‘Brexit’ and Actions Taken by the UK Regulator (So Far)

February 27, 2020 By: Anna Sayre, CSS, Director of Content at ACSS

On January 31, 2020, the U.K. Parliament finally cut ties from the E.U. after two years of grueling debates and discussions in Brussels, signaling a chance for Britain to break away from the E.U. sanctions that it has most dutifully applied for decades. Though itis almost certain that the U.K. will continue to apply most E.U sanctions, it is also looking likely that the U.K. will instill a new sanctions regime of its own, perhaps more closely matching that of its American cousin across the pond.

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Steady Increase in OFAC Enforcement; A Shift Towards Unilateral Sanctions; A New Focus on International Trade; and much more, according to Accuity.

February 3, 2020 By: Anna Sayre, CSS, Director of Content, ACSS

The global sanctions landscape is in a constant state of flux. From the U.S.’ stern outlook on Iran to the E.U.’s ever-tightening sanctions on Russia, our current global climate is ripe for sanctions shifts and new enforcement actions. In fact, 2019 saw the biggest uptick in OFAC cases since 2014, and the number of individual U.S. sanctions cases last year has tripled since the previous year. (more…)

Recent OFAC Settlements with Non-Financial Companies and Lessons Learned

November 4, 2019 By: Thomas Nollner*

A commonly held misconception within the sanctions industry is that Office of Foreign Assets Control (OFAC) sanctions programs only apply to financial institutions. Recent large civil liability settlements between OFAC and several large banking companies support this misconception. As published in the international press, Standard Chartered Bank reached a settlement agreement with OFAC in April 2019 for an apparent violation by paying OFAC $639 million; Societé Génerale S.A. in November 2018 reached a settlement agreement for the same type of apparent violation by paying OFAC $53 million; and J.P. Morgan Chase in October 2018 paid $5 million to OFAC for an apparent violation.

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