OFAC Enforcement Actions By the Numbers: What Makes a Penalty?

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…)

OFAC Enforcement Actions By the Numbers: Who’s At Risk?

Recent Up Tick in Number of OFAC Enforcement Actions against IT/telecom, Offshore Services; California, New York and Texas Companies Most At Risk

October 20, 2017
By Anna Sayre, SanctionsAlert.com

Are you a business that thinks OFAC only takes action against New York-based financial institutions? Think again.

Since 2014, OFAC enforcement actions have significantly increased against non-financial institutions, particularly in IT/telecom and offshore services industries. Furthermore, in addition companies in New York, those in Texas, and especially California, remain highly at risk. (more…)

Cross-Sector Conference in New York Engages Top Experts to Reveal the Trends in Sanctions and Export Controls Risk Management and Enforcement

October 13, 2017

Whether you work at a financial institution or corporation, sanctions compliance comes with a host of risks that require well-developed processes to address them. Such risks were the subject of the inaugural SanctionsAlert.com Sanctions Risk Management Symposium, co-hosted with Compliance Week and Financial Research Associates,which took place in New York last month. Sanctions compliance professionals and experts from companies representing different industries– such as Uber, Standard Chartered Bank, ZTE, AXA Group, Google, and others – gathered in NYC to exchange ideas and discuss their favored processes for mitigating the risks associated with sanctions and export controls. (more…)

Wake Up To Sanctions: SanctionsAlert.com Sanctions Round Up

October 6, 2017

US Substantially Increases Sanctions against North Korea to include Non-U.S. Persons

On September 20, 2017, the U.S. President signed Executive Order (E.O.) 13810 imposing additional sanctions against North Korea targeting trade and financial transactions.This move closely compliments the September 11 resolution by the United Nations Security Council on imposing sanctions on North Korea’s textile and oil industry.

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OFAC Shortens New Debt Maturity Periods under Russian Financial and Energy Sectoral Sanctions

By Peter Jeydel on September 29, 2017

OFAC today revised its Ukraine/Russia-related sectoral sanctions directives prohibiting US person dealings in new debt or new equity of listed Russian financial institutions and new debt of listed Russian energy companies (in both cases, these prohibitions continue to apply to the “interests in property” of the listed entities, meaning any entity 50% or more owned by them). OFAC took this step pursuant to a statutory mandate in the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA).  See our advisory on CRIEEA.  The changes made today are as follows (and as expected based on the statutory mandate): (more…)

SanctionsAlert.com Sanctions Round Up

Sanctions as an Anti-Corruption Tool: South Sudanese Corrupt PEPs Slapped with OFAC Designations
September 18, 2017

On September 6, 2017, pursuant to Executive Order (E.O.) 13664, OFAC added three South Sudanese officials, Malek Reuben Riak Rengu, Michael Makuei Lueth, and Paul Malong Awan, in addition to three companies owned or controlled by Riak Rengu, to the Specially Designated Nationals (SDN) List for their roles in the continued undermining of the peace, security, and stability of the country. As a result of these actions, all of the aforementioned individuals’ and entities’ assets within U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. (more…)