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… and Alfa Laval’s lessons to be learned

Alfa Laval Middle East: Non-U.S. companies should be aware of how their activities might trigger compliance issues with U.S. sanctions, including when they place orders with U.S. affiliates or subsidiaries. This is especially true for companies operating in multiple countries as part of a larger global business organization, and particularly […]

The Alfa Laval Enforcement Actions: the penalty calculations & General Factors

Alfa Laval Middle East: OFAC determined that AL Middle East did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute an egregious case. Accordingly, under OFAC’s Economic Sanctions Enforcement Guidelines (“Enforcement Guidelines”), the base penalty applicable in this matter was $615,844, which was also the applicable statutory […]