Category: OFAC

We were honored to be interviewed for a recent story by The Wall Street Journal about the growing complexity of U.S. sanctions and trade compliance regulations.  The reporter, Mengqi Sun, asked good questions and did a great job portraying the compliance landscape faced by companies today. This statistic from the story is particularly interesting and...

The Export Solutions blog provides timely and helpful information to anyone who is responsible for import/export compliance.  If you haven’t subscribed yet, join our growing community by subscribing now to stay current on all that’s happening in the world of trade compliance. As we say goodbye to 2019, let’s take a look at our top...

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a...

According to Treasury Department statistics, during the first six months of 2019, the Office of Foreign Assets Control (OFAC) has issued nearly $1.3 billion in penalties. That represents 18 settled cases and is an amount which is 17 times greater than all of 2018 (when there were seven settled cases.) The totals for OFAC penalties...

Discussions on the fringes of the G-20 Summit have apparently led to a potential lessening of the restrictions against Huawei and at least some of its affiliates.  These sanctions and the ensuing discussions certainly overshadowed the eight themes of the summit (Global Trade, Economy, Investment, Innovation, Environment and Energy, Employment, Women’s Empowerment, Development and Health). ...

Darus Zehrbach of Westover, West Virginia was recently sentenced to six months in prison for making false statements to a federal agent. Zehrbach applied for an OFAC license to export electric scooters to Iran, however, the license was denied. Despite the denial, Zehrbach exported the scooters from the United States to the United Arab Emirates....

This past December, at the American Bankers Association/American Bar Association Financial Crimes Enforcement Conference, Treasury’s Under Secretary Sigal Mandelker spoke to his audience on the Office of Foreign Assets Control’s (OFAC) Compliance Commitments. While acknowledging that because U.S. economic sanctions can apply to all types of industries and businesses and there may not be a...

In addition to federal workers impacted by the current government shutdown, companies who rely on the federal government to support their import/export compliance are also feeling the impact. We thought it might be helpful to provide the status of the various government agencies involved with assisting importers and exporters during this shutdown. Please Note: This...

We all know that OFAC can impose civil penalties against any person who exports goods to a third party, when that person has reason to believe the goods are destined for Iran. But how far does OFAC have to go to prove that the goods were actually reexported to Iran? A recent decision by the...

Earlier this month, Erdal Kuyumcu, the CEO of Global Metallurgy, LLC, was arrested for allegedly exporting a cobalt-nickel metallic powder from the United States to Iran. According to the Department of Justice press release, Kuyumcu’s company planned to ship the metallic powder through an intermediary in Turkey in order to conceal the ultimate destination of...