Two in one day: new article on

The new article is about the OFAC enforcement action against Kollmorgen Corporation, why the settlement amount was so large compared to the base penalty amount, and what more Kollmorgen could have done.

And I threw in a little snide remark at the end about the AppliChem action – although that was before I figured out that the EU Blocking Statute probably was part of the calculus in that case….

Let me know if you like that one, too…


OFAC Settlements: When Good Intentions Aren’t Enough

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