Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. If you would like to be added to the distribution list, please email me at [email protected].
In addition to a variety of ad hoc designations, below is a summary of key events this past quarter:
- To further increase pressure on the Russian Federation, OFAC has imposed full blocking sanctions on Rosneft and Lukoil. U.S. Persons are prohibited from transacting with both companies, as well as many of their subsidiaries, affiliates, and JVs. OFAC also issued a few General Licenses for wind down periods or to authorize limited transactions.
- The Trump Administration has added Colombia’s President Gustavo Francisco Petro Urrego to the SDN List, as well as several of his associates.
- BIS has implemented its own “50-Percent Rule,” which aligns with the one already established by OFAC. With this rule, BIS has extended its export restrictions to entities owned 50% or more by listed entities.
Click here to download the quarterly update for November.
Additionally, below is a new feature, a summary of the most recent OFAC enforcement actions, with links to my relevant blog posts and the official enforcement release.
FRACHT FWO, INC.
Blog Post | Enforcement Release
Quick Facts
$1,610,775 settlement ($2,147,700 potential liability)
Violations of:
- Venezuela Sanctions Regulations
- Weapons of Mass Destruction Proliferators Sanctions Regulations
- Global Terrorism Sanctions Regulations
- Iranian Transactions and Sanctions Regulations
Key Compliance Lessons
- Embed sanctions screening in urgent transactions.
- Empower compliance over commercial pressure.
- Act swiftly on remediation.
- Integrate multi-layered controls.
- Cooperate fully with OFAC.
SHAPESHIFT AG
Blog Post | Enforcement Release
Quick Facts
$750,000 settlement ($39,515,000 potential liability)
17,183 violations of:
- Cuban Assets Control Regulations
- Iranian Transactions and Sanctions Regulations
- Sudanese Sanctions Regulations
- Syrian Sanctions Regulations
Key Compliance Lessons
- Risk-based compliance is non-negotiable.
- U.S. jurisdiction applies broadly.
- Leverage all available data to support compliance efforts.
- Remediation matters.