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Société Générale expecting to pay $1.3 billion in fines to the U.S. for economic sanctions violations

The French bank is in discussion with U.S. authorities, particularly OFAC,  in resolving fines for facilitating transactions in violation of U.S. economic sanctions. It is currently unknown which sanctions program was violated and the number of transactions and parties involved. This news report may have great implications on the future of banks involvement with Iran post-JCPOA and […]

Amazon Investigation for OFAC Violation

Demonstrating the importance of knowing who you’re doing business with, Amazon, the largest web-based retailer, submitted a voluntary self-disclosure to OFAC for a potential sanctions violation. According to a recent quarterly report from Amazon, it is under federal investigation after selling products to at least one Iranian on the SDN list. Read more here.

OFAC Enforcement Trends

Since the beginning of August, there have been three publicly released enforcement actions by the Office of Foreign Assets Control (OFAC), including two within the same week. These enforcement actions are showing that OFAC is taking a close look at two different things: 1) the constant updating and updated screening of names on one’s list […]

Eliminating Terrorist Financing Without Damaging Legitimate Transactions

Addresses Terrorist Finance Elimination and Legitimate Transaction and Family Remittance Enhancement

Eliminating Terrorist Funding while Enhancing Legitimate Commercial Transactions and Family Remittances There is consensus that financing terrorism, via the international financial system, must be systematically eradicated while maintaining channels for legitimate commercial and family-related financial transactions.  Unfortunately, many international banking conglomerates refuse to do business with certain countries altogether, as their costs of compliance outweigh […]

A Closer Look at OFAC’s General License H

OFAc's General License H: A Closer Look

Back in July (2015) the permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), Germany (collectively the P5+1), the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be exclusively peaceful.

Cash Purchases May Complicate Real Estate Buys From Sanctioned Countries

Real Estate Buys for Immigrants Complicated by Cash Purchases

Heightened Scrutiny of Real Estate Cash Purchases May Complicate Future Buys by Those Tied to Sanctioned Countries On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN) issued two new Geographic Targeting Orders (GTOs) that will temporarily require US title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential […]

North Korea’s Global Weapons Proliferation Network Targeted by OFAC Sanctions

North Korea's Weapons Proliferation Sanctioned

On December 8th, 2015, the Treasury Department’s Office of Foreign Assets Control (OFAC) took aim at the North Korean government’s attempts to procure weapons of mass destruction (WMDs) and related materials for production, presumably for the assembly of a strategic rocket force. Six North Korean nationals and three North Korean shipping companies have been added […]

OFAC Sanctions Prominent Japanese Yakuza Member

Former Yakuza Member Tadamasa Goto Sanctioned

On December 9th 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a press release designating Tadamasa Goto, a Japanese yakuza or gangster member known as the John-Gotti of Japan, as person completely prohibited from dealing with U.S. financial markets.

OFAC Sanctions Three Members of a Powerful Honduran Family and their Bank

Powerful Honduran and Their Bank Sanctioned

On October 7, 2015 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it had made several major designations pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).  OFAC designations (opens as pdf) were made against Jaime Rolando Rosenthal Oliva, along with his son, Yani Benjamin Rosenthal Hidalgo, and […]

Navigators Insurance and The Importance of An OFAC Compliance Program

OFAC Compliance & Navigators Insurance

OFAC Fines Navigators Insurance Company without Compliance Program for Apparent Violations of Various Sanctions Programs. Several interesting things stand out regarding OFAC’s enforcement action against Navigators Insurance Company (“Navigators”).  On August 6, 2015, OFAC entered into a settlement agreement with Navigators to settle potential liability for apparent violations of the North Korea, Iran, Sudan, and […]

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