Between a rock and a hard place: How to ensure sanction compliance when operating a facility in a sanctions-targeted country

June 13, 2017
By Simon Hirsbrunner and Alice Lauterjung

The recently reported resignation of cement manufacturer LafargeHolcim’s CEO has thrown a spotlight on the risks of operating commercial activities in countries targeted by economic sanctions. [1] Without drawing any conclusions on the legal qualification of LafargeHolcim’s conduct in the specific circumstances, the following provides an overview of the principal issues at stake in this case. (more…)

Record-breaking 1.19 Billion Fine for Chinese Tech Giant Demonstrates Broad Extraterritorial Reach of U.S. Export Control Laws

March 22, 2017
By Anna Sayre, Legal Content Writer SanctionsAlert.com

On March 7, three U.S. regulators – the Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of Justice (DOJ) – entered into a coordinated settlement with Zhongxing Telecommunications Equipment Corporation (ZTE), in which the company agreed to a record-breaking combined $1.19 billion in civil and criminal penalties for knowingly shipping illegal telecommunications equipment to Iran and North Korea in violation of U.S. sanctions law. ZTE, a Chinese publicly traded telecommunications manufacturer, is the largest in China and the fourth largest telecommunications manufacturer in the world. (more…)

India’s Upgrade in Export Control Status and Bid to Enter ‘Dual Use’ Controls Club Point to Expansion of Non-Proliferation Efforts

February 2, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

On January 19, 2017, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to implement a new phase of export control cooperation between the U.S. and India.

The new rule marked the first major change to India’s “Validated End User” (VEU) status since July 2009 and follows recognition of India by BIS as a “Major Defense Partner” on June 7, 2016. (more…)

PanAm Seed case shows how (not) to respond when OFAC knocks on the door

October 24, 2016
By: Daniel Calloway, Legal Content Writer, SanctionsAlert.com

On September 13, 2016, Pan American Seed Company, a US-based producer of flower seeds, agreed to pay over $4,000,000 to settle potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations.

The settlement comes after the Office of Foreign Assets Control (OFAC) – the US Treasury’s agency tasked with US sanctions administration and enforcement – allegations that PanAm Seed, indirectly exported flower seeds to two Iranian distributors on 48 separate occasions. (more…)

Alcon to pay $7.6M fine as OFAC takes a harder line against medical tech companies with faulty sanctions compliance programs

October 15, 2016
By: Dan Calloway, Legal Content Writer, SanctionsAlert.com

The Obama administration sent a message this summer that it was taking a more aggressive stance on medical tech firms as it reached its second consecutive and record settlement with a company for exporting medical-use products to sanctioned countries. (more…)