Articles Posted in OFAC

The French bank is in discussion with U.S. authorities, particularly OFAC,  in resolving fines for facilitating transactions in violation of U.S. economic sanctions. It is currently unknown which sanctions program was violated and the number of transactions and parties involved.

This news report may have great implications on the future of banks involvement with Iran post-JCPOA and in violation of U.S. secondary sanctions on Iran.



Demonstrating the importance of knowing who you’re doing business with, Amazon, the largest web-based retailer, submitted a voluntary self-disclosure to OFAC for a potential sanctions violation. According to a recent quarterly report from Amazon, it is under federal investigation after selling products to at least one Iranian on the SDN list.

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An OFAC lawyer discusses the enforcement trends of OFAC and the proper precaution all businesses should take to avoid consequences.Since the beginning of August, there have been three publicly released enforcement actions by the Office of Foreign Assets Control (OFAC), including two within the same week. These enforcement actions are showing that OFAC is taking a close look at two different things: 1) the constant updating and updated screening of names on one’s list when providing services to someone, and 2) taking the proper steps when engaging an activity that would be eligible for a license.

  1. Regularly screening your sanctions list.

On August 2, 2016, OFAC issued a finding a violation to Humana Incorporated, which is the parent company of Kanawha Insurance Company, for violations of the Foreign Narcotics Kingpin Sanctions Regulation. The Foreign Narcotics Kingpin Sanctions Regulations can be found in 31 CFR Part 598.