Finanstilsynet Inspection Report: AP Pension Livsforsikringsaktieselskab
Link: Inspection Report
Two in a week: Payoneer pays OFAC $1,400,301.40 for violating multiple sanctions programs
So, Payoneer apparently violated a number of programs by processing 2,241 payments for parties in Iran, Sudan, Syria and Crimea… and another payments on behalf of parties on the SDN List. The value of the transactions? Less than the fine – only $802,117.36. Why? Because those 2241 violations were not […]
… and Alfa Laval’s lessons to be learned
Alfa Laval Middle East: Alfa Laval Inc: This case demonstrates the importance of implementing effective compliance training to ensure U.S persons know they are generally prohibited from referring business opportunities involving Iran, including to affiliated entities. Such referrals may also increase the likelihood of other, additional sanctions violations being committed. […]
The Alfa Laval Enforcement Actions: the penalty calculations & General Factors
Alfa Laval Middle East: Alfa Laval Inc: Links: Enforcement Actions – Alfa Laval Middle East, Alfa Laval Inc.
…. And Alfa Laval commits to adhering to OFAC’s framework…
Oh, and… Annual Certification: On an annual basis, for a period of five years, starting from 180 days after the date the Agreement is executed, a senior-level executive or manager of Respondent will submit a certification confirming that Respondent has implemented and continued to maintain the sanctions compliance measures as […]
The facts of the 2 Alfa Laval enforcement actions
Link: Settlement Agreement
One company, two enforcement actions…
So, there’s a settlement agreement in the Middle East case, and none in the U.S. case. Why? Well, neither was voluntarily self-disclosed – but the Middle East case was egregious. Seems like an extra level of naming and shaming, since settlements generally contain a greater level of detail of the […]
U.S. charges 4 officers in Chinese state security with hacking campaign
Links: DOJ Press Release Xiao Yang Indictment Wanted Poster
FINTRAC fines Bureau de change Saint-Michel for not registering as an MSB
Link: FINTRAC Notice
FinCEN takes action on no-action (letters)
Maybe they got that idea from OFAC? Links: FinCEN Press Release FinCEN Report
