OFAC $5M Fine Against JPMC Partially Due To Failure in Properly Screening Clients’ Pooling Accounts

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. 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. (more…)

OFAC Fines Epsilon $1.5 Million: Four Lessons for U.S. Exporters With Products In 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. (more…)

Wake Up To Sanctions

SanctionsAlert.comSummer Sanctions Round Up
September 5, 2018

U.S. Cracks Down on Russia with Global Magnitsky Regulations and New Sanctions

As of June 29,2018, the Global Magnitsky Sanctions Regulations (31 CFR part 583) took effect on the Federal Register. These regulations implement the Global Magnitsky Human Rights Accountability Act (or U.S. Global Magnitsky Act) as well as Executive Order 13818 of December 20, 2017.

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Bank of China Order Confirms U.S. Regulators Are Willing to Take a Tough Line On Sanctions Missteps

August 16, 2018
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

After conducting a supervisory examination of its compliance program, the Office of the Comptroller of the Currency (OCC) has issued a $12.5 million fine and a Consent Order requiring Bank of China’s New York Branch to fulfill certain requirements within 90 days, some very far-reaching.

The Order, imposed by the OCC in April 2018, not only details shortcomings found in the Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program of one of the world’s biggest lenders, but also enterprise-wide deficiencies in its Office of Foreign Assets Control (OFAC) compliance requirements.

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‘Sanctions Busting’: The Risks and Rewards to those Trying to Circumvent the System

June 15, 2018
By: Keith Preble and Dr. Bryan R. Early*

The main goal of imposing sanctions on a target country or entity has always been to disrupt the target’s commercial relationships and make it costlier for them to do business. Governments try to achieve this goal by imposing administrative and criminal penalties for individuals and entities that violate their sanctions.

Though these restrictions generally apply only to firms and citizens operating in the country imposing the sanctions, the United States has recently employed far more aggressive and wide-reaching methods in penalizing foreign firms.

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