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OFAC Enforcement Action: Haverly Systems

Interesting case: Haverly settled two Apparent Violations of the Ukraine Related Sanctions Regulations (the first under this program) for $75,375, knocked down from a base penalty of $125,000 (and a maximum of $590,282). The violations were not self-reported, but were non-egregious. The practical upshot is that Haverly invoiced Rosneft (on […]

OFAC plays Musical Lists… 561 out, CAPTA in

Introduction of the Correspondent Account or Payable-Through Account Sanctions (the “CAPTA List”) and Removal of the List of Foreign Financial Institutions Subject to Part 561 (the “Part 561 List”) 3/14/2019 The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is replacing the List of Foreign Financial Institutions Subject to […]

OFAC Enforcement Action: Kollmorgen Corporation

Because Kollmorgen’s Turkish affiliate serviced machines operating in Iran on six occasions, they agreed to a $13,381 settlement. At first glance, it appears that Kollmorgen knew its responsibilities: Kollmorgen acquired control of Elsim in early 2013, thereby making Elsim subject to the ITSR’s prohibitions for any activity or conduct engaged […]

August 15, 2018: a couple of OFAC North Korean designations, plus…

On Wednesday, OFAC designated the following person:  KOLCHANOV, Vasili Aleksandrovich (Cyrillic: КОЛЧАНОВ, Василий Александрович) (a.k.a. KOLCHANOV, Vasiliy Aleksandrovich; a.k.a. KOLCHANOV, Vasily); DOB 25 Mar 1946; Profinet Director General (individual) [DPRK4] (Linked To: PROFINET PTE. LTD.). and entities:  DALIAN SUN MOON STAR INTERNATIONAL LOGISTICS TRADING CO., LTD (Chinese Simplified: 大连天宝国际物流有限公司) (a.k.a. […]

Back up the truck: Russian oligarch assets get frozen (among other things)

Today, OFAC added the following persons:  AKIMOV, Andrey Igorevich, Russia; DOB 1953; POB Leningrad, Russia; Gender Male; Chairman of the Management Board of Gazprombank (individual) [UKRAINE-EO13661].    BOGDANOV, Vladimir Leonidovich, Russia; DOB 28 May 1951; POB Suyerka, Uporovsky District, Tyumen Region, Russian Federation; Gender Male (individual) [UKRAINE-EO13662].    DERIPASKA, Oleg […]