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Enforcement

Articles

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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The Zoltek Experience: Six Lessons for U.S. Companies with Foreign Subsidiaries

February 4, 2019 By: Scott Nance and George Voloshin

On December 20, 2018, the Office of Foreign Assets Control (OFAC) published a penalty notice and settlement agreement with Zoltek Companies, Inc., a U.S. producer of carbon fiber. OFAC found that Zoltek had violated U.S. sanctions laws due to its Hungarian subsidiary, Zoltek ZRT, having purchased inputs from a Specially Designated National (SDN) in Belarus. Zoltek agreed to pay a substantial fine of $7,772,102 and to implement various measures to ensure it would not commit future violations.

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