Menu Home

Crawling from the Wreckage

The newly-posted episode of Mr. Watchlist’s DesigNation is about yesterday’s OFAC enforcement action against Comtech Telecommunications and Comtech EF Data. All you need to know: egregious violations, settlement larger than the base penalty, and only 1 mitigating General Factor… Hoo boy! What fun!

OFAC makes sanctions on Sudan clearer…

Issuance of new Sudan Program and Darfur Sanctions Guidance and a related Frequently Asked Question as well as Frequently Asked Questions Updates and Removals 8/11/2020 The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing Sudan Program and Darfur Sanctions Guidance  and a Frequently Asked Question (FAQ) and removing eleven Sudan-related […]

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 […]