Analysis of suspicious activity reports by the Financial Crimes Enforcement Network indicates nearly $1 billion in suspicious activity in cases of suspected evasion of Russia-related export controls.
Sanctions
Greek shipper fined $2.5M in Iranian oil smuggling case
Empire Navigation pleaded guilty to violating the International Emergency Economic Powers Act by carrying nearly 1 million barrels of Iranian oil from the sanctioned Islamic Revolutionary Guard Corps to another country.
Wise Payments cited for Russia sanctions breaches in landmark OFSI action
U.K.-based foreign exchange service Wise Payments was cited for breaching the country’s sanctions levied against Russia as part of the Office of Financial Sanctions Implementation’s first use of its disclosure enforcement powers acquired last year.
Whistleblower goes above, beyond in Construction Specialties OFAC case
The impact of “see something, say something” was on display as part of Construction Specialties’ settlement with the Office of Foreign Assets Control for apparent Iran sanctions violations.
Construction Specialties to pay $660K in Iran sanctions case
Construction Specialties agreed to pay more than $660,000 in a settlement with the Office of Foreign Assets Control regarding three apparent sanctions violations in Iran carried out by “rogue employees” of its Middle Eastern affiliate.
Neogen discloses avoided OFAC fine in Iran sanctions probe
Neogen Corp. disclosed the Office of Foreign Assets Control concluded a probe into potential sanctions violations regarding transactions by the food and animal safety company with parties in Iran without issuing a fine.
Short seller accuses Freedom Holding Corp. of ‘brazen’ sanctions evasion
Freedom Holding Corp. was accused of “brazen sanctions evasion,” along with openly flouting anti-money laundering and know your customer regulations, as part of an investigative report published by short seller Hindenburg Research.
OFAC doubles down on sanctions against Belarusian regime
The Treasury Department’s Office of Foreign Assets Control announced expanded sanctions against the Belarusian regime three years after the country’s disputed 2020 presidential election.
Common sanctions compliance trip points from 2023 enforcement cases
Penalties against companies including British American Tobacco, Wells Fargo, and Microsoft demonstrate the multiple ways in which businesses can run afoul of U.S. sanctions—an area receiving increased scrutiny by regulators.
Guidance sets self-disclosure expectations for sanctions, export control lapses
Companies seeking credit for voluntarily self-disclosing potential violations of sanctions or export control laws must be mindful of the regimes at play from agencies including the DOJ, BIS, and OFAC and their differing expectations.


