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Wake Up To Sanctions | Second Quarter 2019 – Summer Edition Sanctions Round Up

August 05, 2019

OFAC Publishes New Framework for Compliance Commitments, Naming 5 Essential Components

On May 2, 2019, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) published a Framework for OFAC Compliance Commitments “in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with a framework on the essential components of a sanctions compliance program”. This guidance marks the first time that OFAC has provided prescriptive guidance to companies on its views of what should be included in an effective sanctions compliance program. (more…)

Maritime Shipping Compliance Guidance Focuses on Automatic Identification Systems

June 21, 2019 By: Natasha Bright, Reporter ACSS

Compliance with sanctions isn’t just a bank issue. In the past year, the Office of Foreign Assets Control has begun to focus on industries outside the financial sector including those involved in shipping. Sanctions related to Iran, North Korea and Venezuela have increased pressure on maritime trade businesses including shipping companies, insurance companies, commodities traders, associated financial institutions, and others. In response, organizations are looking for guidance and solutions to adapt to the rapidly evolving and complex compliance landscape

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Business with Iran Through INSTEX: The Viability of Europe’s New Economic Trade Mechanism

June 12, 2019 By: Anna Sayre, Head of Legal Content, ACSS

In early 2019, despite U.S. sanctions to the contrary, Germany, France and the U.K. (also known as the ‘E3’) joined together to set up INSTEX: a new payment channel to facilitate trade with Iran. Though a bold move in theory, any effort on the part of the E.U. to continue trade with Iran could only serve to ruffle Washington’s feathers.

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OFAC Has Increased Its Focus on Iran; Here’s What You Need to Know

May 27, 2019 By: Natasha Bright, reporter ACSS

On the one-year anniversary of the United States withdrawal from the Joint Comprehensive Plan of Action (JCPOA), a new executive order was announced that imposes sanctions on Iran’s iron, steel, aluminum, and copper sectors. This was the latest move in the Trump administration’s “maximum pressure” campaign against Iran, which seems to have picked up speed since the beginning of this year.

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OFAC’s $1.5M Epsilon Fine Provides Four Vital Lessons to U.S. Exporters to Iran

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…)

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