Latest News about Sanctions
WMD Proliferation Detection Can Be Readily Incorporated Into Existing AML/Terrorist Financing Programs, A new Report by the Center for New American Security
The proliferation of weapons of mass destruction (WMDs) is a critical threat facing the international community. As such, finding new and more effective ways of combating the proliferation of WMDs has become a major concern of the international community.
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. Funds in such accounts may belong to multiple persons or belong to only one person, but are often used to make payments to a number of other parties on a periodic basis. Pooled accounts are often used to settle balances between these different entities.
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…)