Category: OFAC

“Toto, I have a feeling we’re not in Kansas anymore.”  Sorry, Dorothy, but we aren’t over the rainbow, either.  Specifically, we’re across the ocean … in a place called Russia.  Talking about a Kansas-based company named (wait for it) … KanRus Trading.  Here’s what transpired in this not-so-fairytale ending. Two Americans stand accused of violating…

In November, Binance Holdings, Ltd. (“Binance”) – the largest cryptocurrency exchange in the world – paid the largest settlement in OFAC history for alleged sanctions violations.  Together with other agencies, the settlement totaled over $4 billion!  On top of that, the CEO also pled guilty, has relinquished his role, and must pay a personal fine…

If you’ve spent the last year-and-a-half focused on Russia, hold that thought, and don’t take your eye off other bad actors around the world.  That’s what the U.S. Government is warning with its third joint notice, published earlier this month. The previous two notices were specific to Russia.  Now, the new notice warns U.S. institutions…

Most of us are familiar with, or even actively participate in, rewards programs.  Maybe it’s through your place of employment or your favorite store.  The rewards program can include consumer rebates and loyalty programs, sales incentives and employee rewards and recognition in the form of prepaid gift cards; perhaps to a local coffee chain, holiday…

Stop me if you’ve heard this one:  “We don’t make munitions or sell weapons, so we are good on all those export-law requirements.” Statements like this make most trade compliance managers cringe.  Why?  Because there’s so much more to import/export compliance than just “selling munitions.”  I can remember a case, years ago, when GEICO got…

Whether you’re a business owner, financial professional, or anyone transacting globally, understanding the Office of Foreign Assets Control (OFAC) is crucial. OFAC plays a vital role in enforcing economic and trade sanctions against targeted individuals, organizations, and countries. Our team helps companies in various industries maintain OFAC compliance, and today we will take a deep…

Another day.  Another restriction against China. Earlier this month, President Biden signed an executive order targeting U.S. investment in certain national security technologies where that investment involves “countries of concern.”  Currently, these “countries of concern” are China, Hong Kong and Macau … but mostly, China.  On the same day this order was signed, the Treasury…

In the 2008 comedy Burn After Reading, Brad Pitt and Francis McDormand play two clueless gym employees who try (and fail) to make money selling government secrets.  And while bribery, espionage and money laundering sound like all the good plot points for any spy comedy, you don’t expect to find them in the real world…

On July 26th, U.S. government agencies published a “tri-seal note” describing the Voluntary Self-Disclosure (VSD) policies applicable to export controls.  This is the second joint document issued by three key U.S. regulators – the Department of Commerce, Bureau of Industry and Security (BIS), the Department of the Treasury, Office of Foreign Assets Control (OFAC), and…

Not surprisingly, last month’s G7 Summit solidified the persistent and unified commitment in support of Ukraine through new sanctions and export restrictions on Russia and Belarus.  The purpose remains the same – the G7 countries’ continuation to cripple Russia’s ability to source goods and technology required for the war in Ukraine. This results in the…