Naming and shaming? Fair approach? Expert views mixed on OFSI’s Wise Payments case
The recent decision by the U.K. Office of Financial Sanctions Implementation to disclose details of how Wise Payments failed to stop an individual from obtaining cash while subject to Russian sanctions has ignited debate about whether the agency is taking the right enforcement approach.
3M to pay $9.6M over Iran sanctions lapses
The Office of Foreign Assets Control ordered multinational conglomerate 3M to pay more than $9.6 million over apparent Iran sanctions violations by its subsidiary and a U.S. employee of a separate subsidiary.
Emigrant Bank to pay $32K in Iran sanctions case
New York-based Emigrant Bank agreed to pay nearly $32,000 as part of a settlement with the Office of Foreign Assets Control addressing apparent sanctions violations regarding an account it maintained for a pair of Iranian residents.
DOJ official: Compliance must have ‘prominent seat’ at M&A decision table
The Department of Justice is gearing up to provide more guidance on voluntary self-disclosures in the mergers and acquisitions space and the role compliance should play.
SEC: Investment adviser to sanctioned Russian oligarch failed to register
The Securities and Exchange Commission announced charges against New York-based Concord Management and its owner for operating as an unregistered investment adviser to a lone client: a sanctioned Russian oligarch.
New OFAC sanctions expand clamps on Russia tech supply chain
The Office of Foreign Assets Control widened its area of focus to disrupt Russia’s technology supply chain with new sanctions announced against entities in Finland and Turkey.
DOJ appoints leaders for corporate enforcement program
The Department of Justice announced new positions in its National Security Division to support the agency’s crackdown on sanctions evasion, export control violations, and other forms of economic crime.
FinCEN analysis: Trends in Russia export control evasion attempts
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.
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.
Fed fines Deutsche Bank $186M over historic sanctions, AML lapses
The Federal Reserve Board fined Deutsche Bank $186 million regarding violations of previous consent orders addressing alleged sanctions and anti-money laundering weaknesses and control failures relating to the bank’s relationship with Danske Estonia.
Potential sanctions violations: To voluntarily self-disclose or not?
The Department of Justice scrutinizing sanctions on par with how it views bribery under the Foreign Corrupt Practices Act alters the calculus of whether a company should voluntarily self-disclose potential violations, experts discussed at CW’s TPRM Summit.
OFAC head Andrea Gacki shifted to lead FinCEN
Treasury Secretary Janet Yellen announced the appointment of Andrea Gacki as director of the Financial Crimes Enforcement Network.
G7 task force to aid crack down on corruption in Ukraine
The Group of Seven justice ministers announced a Japan-led joint task force to “help Ukraine strengthen the rule of law and fight corruption,” according to U.S. Deputy Attorney General Lisa Monaco.
OFAC orders Swedbank Latvia to pay $3.4M over Crimea sanctions violations
Swedbank Latvia agreed to pay more than $3.4 million to resolve apparent U.S. sanctions violations in the Crimea region of Ukraine, the Office of Foreign Assets Control announced.
DXC Technology self-reports possible Russian sanctions violations
DXC Technology Company disclosed it might have violated U.S. sanctions and export controls against Russia in its sale of a Russian subsidiary.
U.S. reinvigorates anti-Russia push with new sanctions, guidance
The United States once again ratcheted up sanctions against Russia in an attempt to further choke off the funds and military supplies the country is using in its war against Ukraine.
Highlights from Compliance Week 2023
Significant changes in policy and technology, in addition to fresh perspectives on tried-and-true compliance topics, highlighted the discussion at Compliance Week’s 2023 National Conference.
Murad to pay $3.3M for ‘egregious’ Iran sanctions lapses
California-based cosmetics company Murad, a subsidiary of Unilever, agreed to pay $3.3 million as part of a settlement with the Office of Foreign Assets Control addressing apparent Iran sanctions violations over an eight-year period.
Amex GBT navigates tricky 2022 to win Compliance Program of the Year
Going public, sanctions, a key merger. For its navigating a series of competing compliance challenges while maintaining trust with clients and travelers, American Express Global Business Travel was honored as Compliance Program of the Year at the 2023 Excellence in Compliance Awards.
U.S. set to expand sanctions in Sudan
The United States is preparing to issue sanctions on individuals and entities it considers responsible for perpetrating civil unrest in Sudan.
Crypto exchange Poloniex to pay $7.6M in OFAC sanctions case
Cryptocurrency exchange Poloniex agreed to pay nearly $7.6 million as part of a settlement with the Office of Foreign Assets Control for engaging with more than 200 customers across a handful of sanctioned regions.
Attorney pleads guilty to aiding sanctioned Russian oligarch
New York attorney Robert Wise faces up to five years in prison after pleading guilty to making payments to maintain U.S. properties secretly owned by sanctioned Russian oligarch Viktor Vekselberg.
British American Tobacco to pay $635M in North Korea sanctions case
British American Tobacco will pay more than $635 million to settle allegations the company violated U.S. sanctions against North Korea using a complex, yearslong scheme to import tobacco products into the country.
Business orgs fined $84K by DOJ over sanctioned Iran dealings
Taiwan-based DES International Co. and Brunei-based Soltech Industry Co. each agreed to pay fines of $83,769 after pleading guilty to Department of Justice charges of conspiring to violate U.S. export laws and sanctions by sending U.S.-origin goods to Iran.
OFAC sanctions International Investment Bank over Russian ties
The International Investment Bank, a multinational development institution headquartered in Hungary, was designated by the Office of Foreign Assets Control for potentially facilitating the evasion of U.S. sanctions against Russia.
Microsoft to pay $3.3M to settle sanctions, export control violations
Microsoft will pay more than $3.3 million to settle charges from the Office of Foreign Assets Control and Bureau of Industry and Security its subsidiaries violated sanctions laws and export controls across their dealings in four sanctioned countries and Ukraine’s Crimea region.
Uphold HQ fined $72K in OFAC sanctions case
Uphold HQ will pay $72,230 to settle charges levied by the Office of Foreign Assets Control that it processed sanctioned transactions for persons in Iran and Cuba and government employees in Venezuela.
Wells Fargo fined $98M for facilitating sanctions violations in Iran, Syria, Sudan
Wells Fargo will pay nearly $98 million to settle charges a subsidiary facilitated more than $532 million worth of prohibited transactions in violation of sanctions against Iran, Syria, and Sudan.
Swedbank reserves $3.7M for OFAC settlement
Swedbank said it expects to pay 40 million Swedish krona (U.S. $3.7 million) as part of a settlement with the U.S. Treasury’s Office of Foreign Assets Control related to apparent sanctions violations.
U.S. authorities list red flags for sanction evasion by third parties
The Bureau of Industry and Security, Office of Foreign Assets Control, and Department of Justice issued guidance to highlight common methods bad actors use to evade sanctions and export controls on Russia and how to spot their use.
Godfrey Phillips India to pay $333K in North Korea sanctions case
Tobacco company Godfrey Phillips India agreed to pay $332,500 to the Office of Foreign Assets Control to settle charges it violated U.S. sanctions by involving U.S. banks and bank personnel in payments for shipments to North Korea.
OFAC imposes new sanctions to mark anniversary of Russia’s Ukraine invasion
The Office of Foreign Assets Control unveiled a slew of new sanctions against financial services firms and individuals that either support Russia’s war effort or have been judged to be undermining existing U.S. sanctions.
Treasury No. 2 warns of increased Russian sanctions enforcement
Deputy Secretary of the Treasury Wally Adeyemo said the agency is primed to step up its enforcement efforts regarding sanctions and export controls announced against Russia in the year since the country invaded Ukraine.
Raiffeisen confirms OFAC probe into Russia, Ukraine business
Raiffeisen Bank International said it received a request for information from the Treasury Department’s Office of Foreign Assets Control regarding its business activities related to Russia and Ukraine.
Ethical culture strengthened by 2022 challenges, survey finds
LRN’s annual ethics and compliance benchmarking report found most respondents—85 percent—said their company’s ethical culture has been strengthened, not weakened, in facing the Covid-19 pandemic, Russia’s war in Ukraine, supply chain disruptions, and more.
Banks fooled in DOJ Russian yacht sanctions evasion case
The Department of Justice’s charges against a U.K. businessman and his Russian partner for evading U.S. sanctions against a Russian oligarch provide insight into how the use of shell companies, third parties, and other methods can thwart the compliance efforts of financial institutions.
Crypto exchange Bitzlato shut down, labeled ‘money laundering concern’
The Financial Crimes Enforcement Network designated Bitzlato, a Hong Kong-registered cryptocurrency exchange, as a “primary money laundering concern” in the first use of a law that targets entities that facilitate illicit Russian financial transactions.
Danfoss to pay $4.4M in OFAC sanctions settlement
Danish manufacturer Danfoss agreed to pay nearly $4.4 million to settle allegations a subsidiary violated U.S. sanctions by running payments from customers based in Iran, Sudan, and Syria through the foreign branch of a U.S. financial institution.
FinCEN report identifies financial trends of Russian oligarchs
The Financial Crimes Enforcement Network published an analysis of financial trends involving Russian oligarchs and how U.S. financial institutions have aided in the identification of more than $30 billion worth of sanctioned Russians’ assets.
AML 2023 preview: Regs not backing down on beneficial ownership, tech needs
Keeping up with increasingly demanding anti-money laundering expectations in 2023 will likely mean doing more with less and figuring out where and when is the best place to use technology to aid compliance, experts say.
Managing sanctions risk: Keys to successful implementation
The International Compliance Association hosted a webinar looking at challenges faced by organizations regarding changes in the sanctions landscape in 2022. Holly Thomas-Wrightson offers a recap of the discussion.
Tricky but doable: Tips for navigating sanctions in third-party relationships
Sanctions concerns don’t need to end all business relationships in high-risk regions. Experts at CW’s virtual TPRM and Oversight Summit share their experiences navigating compliance.