Tag Archives: OFAC

Clarity Required: Iran Sanctions Convictions Reversed in U.S. v. Banki

By: Thad McBride and Mark L. Jensen Introduction: On October 24, 2011, a three-judge panel of the U.S. Court of Appeals for the Second Circuit released an opinion in United States v. Banki, No. 10-3381 (2d Cir. Oct. 24, 2011) that reversed convictions of Defendant Mahmoud Reza Banki on charges of conspiring to violate the … Continue Reading

OFAC, BIS Double Up Flow Serve: What the Flowserve Settlement Says About Corporate Compliance Programs

By Thaddeus McBride, Mark Jensen, & Corey Phelps In late September, Flowserve Corporation (“Flowserve”) and a number of its subsidiaries agreed to settle alleged export violations with the Department of Commerce, Bureau of Industry of Security (“BIS”) for $2.5 million, and to remit $502,408 to the U.S. Department of the Treasury, Office of Foreign Assets Control … Continue Reading

OFAC Settles Alleged Sanctions Violations for $88.3 million

By Thaddeus McBride & Mark Jensen On August 25, 2011, a major U.S. financial institution agreed to pay the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) $88.3 million to settle claims of violations of several U.S. economic sanctions programs. While OFAC settlements with financial institutions in recent years have involved larger penalty amounts, … Continue Reading

Syria Update: Significant New Sanctions Imposed

By Thaddeus McBride , Reid Whitten & Corey Phelps On August 18, 2011, based on the “continuing escalation of violence against the people of Syria,” President Barack Obama issued Executive Order 13582 (“EO 13582”) to expand significantly U.S. sanctions on Syria.  This briefing summarizes those sanctions as well as the General Licenses issued—first on August 18 … Continue Reading

Trading Up: Newly Implemented North Korea and Libya Sanctions

By Scott Maberry, Thad McBride, Mark Jensen, and Corey Phelps In recent weeks, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) has updated the sanctions regulations it administers against Libya and North Korea. These recently implemented sanctions continue OFAC’s trend towards precise, targeted sanctions; moreover, the way in which OFAC amended its sanctions … Continue Reading

New Sanctions Block Continuing Performance Of Libyan Government Contracts In Addition To Targeting Col. Qadhafi’s Assets

By Curtis M. Dombek On February 25, 2011, the President issued an Executive Order blocking not only the assets of Muammar Qadhafi, Ayesha Qadhafi, Khamis Qadhafi, Mutassim Qadhafi, and Saif Al Islam Al Qadhafi, but also blocking all assets of the Government of Libya, as follows:   “All property and interests in property that are in the … Continue Reading
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