October 29, 2018 By: Scott Nance*
In order to optimize interest and improve liquidity for their clients, financial institutions frequently maintain so-called ‘pooling accounts’, in which funds from many different accounts are combined.
October 3, 2018 By: SanctionsAlert.com
On September 13, 2018, Epsilon Electronics Inc, a car audio and video equipment manufacturer, agreed to pay the U.S. Treasury’s Office of Foreign Assets Control (OFAC) $1,500,000 to settle a case related to alleged violations of the Iranian Transactions and Sanctions Regulations.
The case, which is a culmination of a 2014 penalty notice and two court cases, contains four vital lessons for U.S. exporters whose products may be found in Iran.
The September 2018 settlement is a re-consideration of a disputed penalty notice from 2014, at which time OFAC fined Epsilon $4,000,000. In the 2014 notice, OFAC alleges that from 2008 to 2012, the electronics manufacturer broke the law by selling audio and video equipment to Asra International, LLC. (more…)
SanctionsAlert.com Summer Sanctions Round Up
September 5, 2018
U.S. Cracks Down on Russia with Global Magnitsky Regulations and New Sanctions
As of June 29,2018, the Global Magnitsky Sanctions Regulations (31 CFR part 583) took effect on the Federal Register. These regulations implement the Global Magnitsky Human Rights Accountability Act (or U.S. Global Magnitsky Act) as well as Executive Order 13818 of December 20, 2017.
August 16, 2018
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com
After conducting a supervisory examination of its compliance program, the Office of the Comptroller of the Currency (OCC) has issued a $12.5 million fine and a Consent Order requiring Bank of China’s New York Branch to fulfill certain requirements within 90 days, some very far-reaching.
The Order, imposed by the OCC in April 2018, not only details shortcomings found in the Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program of one of the world’s biggest lenders, but also enterprise-wide deficiencies in its Office of Foreign Assets Control (OFAC) compliance requirements.
June 15, 2018
By: Keith Preble and Dr. Bryan R. Early*
The main goal of imposing sanctions on a target country or entity has always been to disrupt the target’s commercial relationships and make it costlier for them to do business. Governments try to achieve this goal by imposing administrative and criminal penalties for individuals and entities that violate their sanctions.
Though these restrictions generally apply only to firms and citizens operating in the country imposing the sanctions, the United States has recently employed far more aggressive and wide-reaching methods in penalizing foreign firms.
Cuba, Iran, Sudan Top the List of OFAC Actions; Recent Trend Suggests Voluntary Disclosure Could Mitigate Penalty Amount
November 7, 2017
By Anna Sayre, SanctionsAlert.com
The dread of an OFAC penalty is something that no institution or company wants to face. But the Iran and Cuba sanctions regimes are more frequently enforced than others. The amount of sanctions enforcement cases based on violations of these two programs dwarfs any others by a wide margin. And, once you find out that your company has made a sanctions misstep, and you tell OFAC about it, you may mitigate the penalty amount.Since 2013, the benefits of voluntary disclosure have begun to show as part of a downward trend. (more…)