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…
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…
The New York branch office of the National Bank of Pakistan (NBP) has agreed to pay $28,800 to settle alleged violations of the Office of Foreign Assets Control (OFAC) Global Terrorism Sanctions Regulations. This stems from a series of funds transfers processed by the bank to an entity on OFAC’s Specially Designated Nationals (SDN) List….
Last week, oil and gas giant Schlumberger plead guilty to facilitating trade with Iran and Sudan, in violation of U.S. sanctions. The parent company’s Schlumberger Oilfield Holdings Ltd. (SOHL), which is a wholly-owned subsidiary of Schlumberger Ltd., agreed to a guilty plea for conspiring to violate the International Emergency Economic Powers Act (IEEPA) by willfully…
One of the myths I often hear from foreign companies is that they’re not subject to the jurisdiction of U.S. export control regulations. Like so many myths, I think some people believe that if they simply repeat this often enough, it will eventually become true. (Never mind that the file cabinets of U.S. export enforcement…
There’s a lot of chatter among the export control community this week about the status of export license applications and other activities in light of the U.S. federal government shutdown. Some of the questions I’ve seen posted to discussion boards and blogs include: And my personal favorite … In some ways, I think it’s too…
An Australian man and his company have been charged with several counts of violating the EAR and ITAR (as well as OFAC trade embargoes). The charges point to an alleged scheme to export restricted items from the U.S. to Australia, for transshipment to Iran, in violation of numerous export control regulations. According to the Department…