OFAC

BIS
China
Commerce Department
Global Trade
OFAC
Sanctions
SDN

Huawei Temporary License Issued

May 23, 2019:  Effective May 20, 2019, the BIS issued a 90 day license for Huawei and its related entities that were added to the OFAC’s SDN list earlier this month.  This general license is temporary, and will run out on August 19, 2019.  Not all transactions are allowed – check the license language for […]

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Best Practices & Resources
Global Trade
OFAC

OFAC’s Framework for Compliance Commitments

Earlier this month, OFAC published a guidance on compliance commitments.  The full name is A Framework for OFAC Compliance Commitments and you can access it by clicking the foregoing hyperlink. OFAC lists the following 5 essential components of compliance: Management Commitment: OFAC stresses the importance of a “culture of compliance” that is built from top […]

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Global Trade
OFAC
Sanctions
SDN
Venezuela

Venezuelan Defense & Oil Sectors – OFAC Sanctions

May 10, 2019:  The US Treasury identified the Venezuelan defense sector as a subject to its sanctions.  The May 10 designations were in response to SEBIN’s illegal arrests of National Assembly members and intend to target those actors who have had a hand in the repressive Maduro defense and intelligence sector.  SEBIN is a is […]

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Freshly Brewed
Global Trade
Iran
OFAC
Sanctions

New Executive Order: Targeting Iran’s Metals Sector

Yesterday, the Trump administration issued an Executive Order (“EO”) to take steps to deny Iran revenue derived from exports of Iranian metals that may be used to fund or support the proliferation of WMDs and terrorist activities.  According to the EO, US persons cannot operate or engage in the Iranian metals sector, engage in significant […]

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Cases
Iran
OFAC
SDN

MID-SHIP Group: OFAC Settlement

Last week, OFAC announced that it has reached a $871,837 settlement with MID-SHIP Group LLC (“MID-SHIP”). The Settlement Agreement notes that in 2011, MID-SHIP (a ship broker) processed transfers of funds related to payments  for five apparent violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations. OFAC Notice, Settlement Agreement and Enforcement Information. Per the […]

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Cases
Cuba
Global Trade
Iran
OFAC
Sanctions

Treasury Department’s OFAC – UniCredit Bank Settlements

Earlier this month, OFAC announced 3 settlements totaling $611M with 3 UniCredit Group Banks located in Germany, Austria and Italy.  This was a part of a $1.3B settlement of the banks with other federal and state governments and agencies. OFAC investigated the banks in connection with violations of US sanctions on Burma, Cuba, Iran, Libya, Sudan, […]

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Anti-Corruption
Global Trade
OFAC
Sanctions
Venezuela

Treasury Sanctions Venezuelan Minister of Foreign Affairs

April 26, 2019:  OFAC sanctioned Jorge Alberto Arreaza Montserrat, the Venezuelan Minister of Foreign Affairs, and Carol Bealexis Padilla de Arretureta, both of whom were determined to be current or former officials of the Maduro Government of Venezuela. For information about the methods that Venezuelan senior political figures, their associates, and front persons use to […]

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Fraud
OFAC
Sanctions

Foreign Interference With US Elections Sanctions

April 29, 2019:  OFAC added regulations to implement the September 12, 2018 Executive Order 13848, which declared a national emergency in response to foreign interference in US elections. The EO authorized sanctions against any foreign government, entity or individual that authorizes, directs, sponsors, or otherwise supports interference with US elections. The regulations took effect yesterday, […]

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Freshly Brewed
Global Trade
Iran
OFAC
Sanctions

Stanley Black & Decker OFAC Settlement: Iran Exports

March 28, 2019:  Yesterday, the Treasury Department issued a notice of settlement with Stanley Black & Decker, Inc. and its Chinese subsidiary for alleged violations of Iran sanctions.  The $1,869,144 settlement is related to allegations that in 2013 and 2014 the Chinese sub “exported and attempted to export 23 shipments of power tools and spare […]

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Global Trade
OFAC
Sanctions
SDN

OFAC Sanctions – DRC: Congolese Officials

Last week, OFAC added Congolese officials on its SDN list due to their activities that undermined DRC elections.  As the Treasury release notes, “[t]his action follows persistent corruption by senior officials within the DRC’s National Independent Electoral Commission (CENI) and the former Kabila Government to obstruct and delay preparations for credible and inclusive elections.”  The three […]

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