Gil Travel Enforcement Action Teaches Lesson About Compliance
On October 27, 2015, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a web…
Where’s the Beef (in First Data’s Settlement)?
On April 15, United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) settled with Atlanta-based First Data…
Does the PayPal Settlement Set a Dangerous Precedent?
Last week, PayPal agreed to cough up $7,658,300 for violations of a number of different sanctions programs. Between 2009 and…
OFAC Finally Receives A Challenge To An Enforcement Action: The Case Of Epsilon Electronics
Every few months we hear the news reports about the United States Department of the Treasury’s Office of Foreign Assets…
OFAC Can Be Hazardous To Your Health (Insurance Provider)
This post may not be reaching the correct audience, but for those not aware, there’s an arm of the United…
Tailspin: The Fokker Saga Part II
On June 8, I posted an article related to the Fokker Services (“Fokker”) criminal case pending in the United States…
Are You Fokkers Crazy?!?!?!
On Thursday, the United States Department the of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced an agreement to…
Iranian Bank Accounts: Criminal Or Civil Or Neither?
We frequently get calls where clients want to know the “approved” banks in Iran they can work with or have…
The FBAR-IEEPA One-Two Punch On Accounts In Iran
Yesterday, I wrote on what U.S. banks should do in regards to servicing accounts for parties located in Iran. Today,…
Royal Bank Of Scotland Takes A Hit And OFAC Tells All
Typically when there is a civil penalty announcement by the United States Department of the Treasury’s Office of Foreign Assets…