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… 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. […]

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 […]