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Thanks, Yoshi!*

The recent enforcement action against Essentra FZE also come with a settlement agreement. However, although a link is posted on the Recent Actions page, you can’t get to it from the list of enforcement actions OFAC maintains. The settlement is posted below – and adds some additional detail of the […]

Suspicions confirmed…

OFSI corrects six listings OFSI has removed 5 individuals and amended 1 on the consolidated list. North Korea (DPRK) regime: The entry for Ri Pyong Chol (Group ID: 13546) has been removed. Democratic Republic of the Congo regime: The entries for Robert Kibelisa (Group ID: 13437) and Lambert Mende (Group ID: […]

One last one: OFSI removes 1 from DPRK sanctions

Today, UK regulators removed: 1. CHOL, Ri Pyong DOB: –/–/1948. Position: First Vice Director, Munitions Industry Department Other Information: As First Vice Director of the Munitions Industry Department, holds a pivotal position within the DPRK’s ballistic missile programme. Annex XIII. Listed on: 16/10/2017 Last Updated: 18/07/2019 10/07/2020 Group ID: 13546. […]

OFAC Enforcement Action: Amazon.com

The settlement: $134,523 The base penalty: $134,523…. but the statutory maximum was $1,038,206,212 What were the actual violations? From on or about November 15, 2011, to on or about October 18, 2018, persons located in Crimea, Iran, and Syria placed orders or otherwise conducted business on Amazon’s websites for consumer […]

What about a SHTA for North Korea?

That’s the subject of my new article for Regulation Asia – Humanitarian Trade with North Korea: A Matter of Trust. It’s not just finding a government that will provide a clearinghouse for the transactions and the associated due diligence and reporting – it’s navigating the geopolitics, too. Let me know […]