Enforcement Actions
Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Park Strategies, LLC 1/21/2020 The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced that Park Strategies, LLC (“Park Strategies”), a lobbying firm located in New York, New York, has paid […]
Allianz agreed to pay $170,535 for 6474 voluntarily self-disclosed, non-egregious apparent violations of the Cuban Asset Control Regulations (CACR), reduced from a base penalty of $270,690.90. Here is the narrative of what Allianz did: Between August 20, 2010 and January 15, 2015, AGR Canada fronted travel insurance policies that included […]
Simply put, Chubb Corporation merged with ACE Limited, and one of ACE’s subsidiaries was subject to US jurisdiction (because one of its parents was incorporated in the US). And that subsidiary apparently violated the Cuban Assets Control Regulations(CACR) 20,291 times. The huge bulk of these were premium payments for Cuba-related […]
OFAC Issues a Finding of Violation to Aero Sky Aircraft Maintenance, Inc. for Violations of the Global Terrorism Sanctions Regulations: OFAC has issued a Finding of Violation to Aero Sky Aircraft Maintenance, Inc. (“Aero Sky”), a Texas company located in San Antonio, that negotiated and entered into a contract and […]
News Release 2019-138 | November 21, 2019 OCC Enforcement Actions and Terminations WASHINGTON—The Office of the Comptroller of the Currency (OCC) today released new enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with national banks and federal savings associations. All Cease and Desist Orders, Civil Money […]
U.S. Department of State Concludes $1,000,000 Settlement of Alleged Export Violations by AeroVironment, Inc. MEDIA NOTE OFFICE OF THE SPOKESPERSON NOVEMBER 20, 2019 Share The Department of State has concluded an administrative settlement with AeroVironment, Inc. (AV) of Simi Valley, California, to resolve alleged violations of the Arms Export Control […]
Apple paid $466,912 for non-egregious, self-reported violations of the Kingpin Act, as opposed to the base penalty amount of $576,434 and the maximum civil monetary penalty of $74,331,860. Turns out they had a developer company in the App Store who was an SDN, and whose account administrator was, too – […]
Notice Notice to exporters 2019/15: UK exporters fined for unlicensed exports Published 12 November 2019 Between May and October 2019, HM Revenue & Customs (HMRC) issued compound penalties between £5,000 and £90,000 to 9 UK exporters. These related to unlicensed exports of dual use goods, military goods and related activity […]
So, Apollo (now called Carlyle Aviation Partners Ltd) had 12 apparent violations of the Sudanese Sanctions Regulations for leasing aircraft engines to a company, which subleased them to another, which installed them on aircraft belonging to the SDN Sudan Airways. The lease agreements contained provisions prohibiting the lessee from transferring […]
On 8 May 2019, the Central Bank of Ireland (the “Central Bank”) reprimanded and imposed a fine of €280,000 on Campbell O’Connor & Company (the “Firm”) for five breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “CJA 2010”). The Firm has admitted the breaches. The […]
