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The OFAC Book of Why: Cuba Sanctions (Part 1)
Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. The OFAC...
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The OFAC Book of Why: Cuba sanctions (Part 2)
Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. Very...
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The OFAC Book of Why: Cuba sanctions (Part 3)
Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. Now, for...
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The OFAC Book of Why: Cuba sanctions (Part 4)
Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. Now, for...
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Even non-profits can get fined…
The American Steamship Owners Mutual Protection and Indemnity Association, Inc. (the “American Club”) just got fined $348,000 for 55 non-egregious violations of the Cuban, Iranian and Sudanese...
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That’s a lot of lira… Intesa Sanpaola fined $2.9MM…
…for violations of the Sudanese, Cuban and Iranian sanctions programs. Most notable is the following: As early as the late 1990s, Intesa maintained a customer relationship with Irasco S.r.l....
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OFAC Enforcement Action: Amex Travel Related Services shows how it’s NOT done
The base penalty: $3,629,250 The final penalty: $5,226,120 – the first time Mr. Watchlist has ever seen the penalty be higher than the base. The offense: Despite being warned, in writing, in 1995,...
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July 30, 2013: OFAC updates Cuba, Narcotics sanctions
Monday, OFAC made two sets of sanctions changes. First, they removed the following vessels from the Cuban sanctions program: ACECHILLY (Acechilly Navigation Co., Malta) (vessel) [CUBA]. ACEFROSTY...
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OFAC Enforcement Action: $39,501 Fine for World Fuel Services Corporation
The Miami firm facilitated provision of goods and services for a ship docked in Iran and for a plane that touched down in Khartoum, Sudan by non-US affiliates of the firm. It also provided services for...
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Ameron International coughs up $434,700 in OFAC fines
This settlement was for violations of the ITSR (Iranian Transactions and Sanctions Regulations) and the CACR (Cuban Assets Control Regulations) in 2005 and 2006. The base penalty for these violations,...
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OFAC Enforcement Action Against Weatherford International Ltd
The Swiss oil services company, which has US operations and which trades on the NY Stock Exchange, has agreed to a civil monetary penalty of $91,026,450 for transactions with Cuba, Iran and Sudan...
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OFAC Enforcement Action: Royal Bank of Scotland pays $33,122,307
This was a big one – OFAC didn't hide this one behind an anonymous link like most of them are. The bank violated Burmese, Iranian, Sudanese and Cuban sanctions. These were egregious violations, but...
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More than meets the eye: Ameron International
Earlier this year, Ameron International, now a subsidiary of National Oilwell Varco (as of 2011), agreed to a settlement with OFAC for violations of the CACR (Cuban Assets Control Regulations) and the...
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OFAC Enforcement Action: No se puede viajar a Cuba!
CWT BV was a Netherlands-based travel services company. In 2006, however, its majority ownership changed to US owners, which made it subject to OFAC sanctions. And they didn't stop helping to fly folks...
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OFAC Enforcement Action: AIG fined $279,038 for Cuban sanctions violations
There were 3,560 non-egregious, voluntarily self-disclosed violations between 2006 and 2009, for a base penalty of $413,390. Here's what happened: Between January 2006 and March 2009, two AIG...
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OFAC Enforcement Action against Decolar.com, Inc.
The company, whose HQ is in Buenos Aires, but who is incorporated in Delaware, was fined $2,809,800 on Tuesday for violations of the Cuban Asset Control Regulations, for providing air and hotel travel...
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Sacrebleu!
No need for any more in the title – BNP just got whacked for the largest set of civil monetary penalties ever. It's a little deceptive when you first look at OFAC's notice, which only mentions one...
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BNP compliance officers warned upper management
Quoting the Wall Street Journal's Risk and Compliance Blog, the FCPA blog notes multiple cases in the guilty plea where BNP staff warned management that it was exposed to regulatory liability: In 2005,...
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August 20,2014: Belarus, Kingpin Act and Cuba sanctions changes by OFAC
On Wednesday, OFAC added the following to the SDN List under its Kingpin Act anti-narcotics trafficking sanctions: VALLE VALLE, Jose Reynerio; DOB 15 Jan 1974; nationality Honduras (individual)...
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September 30, 2014: OFAC updates Cuba, narcotics, terror sanctions
On Tuesday, OFAC removed the following cargo vessels from the Cuban sanctions program: EAST ISLANDS (C4QB) General Cargo 15,120DWT 8,996GRT Cyprus flag (EAST ISLAND SHIPPING CO. LTD. (SDN)) (vessel)...
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