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.
April 23, 2019 By: Scott Nance*, Principal, LC Consulting
Recent times have seen an uptick in sanctions enforcement actions, placing an onus on many compliance suites and officers to take head and build a robust sanctions compliance program.
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.
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…)