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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 […]

The fun starts on page 14…

of the Standard Chartered settlement with OFAC – it’s a roadmap to what real remediation looks like, and the standards for a firm of size and commercial sophistication are: Specifically, OFAC and Respondent understand that the following compliance commitments have been made: a. Management Commitment: i. Respondent commits that Senior […]

Mr. Watchlist said there was more…

Department of Justice U.S. Attorney’s Office Southern District of New York   Manhattan U.S. Attorney Announces Criminal Charges Against Société Générale S.A. For Violations Of The Trading With The Enemy Act Bank to Pay Total Penalties of more than $1.3 Billion as part of Resolution with Federal and State Prosecutors […]