Blog
Quarterly Trade Compliance Update – July 2025
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. In addition to a variety of ad hoc designations, below is a summary of key events this...
OFAC Fines Harman International $1.4 Million for Iran Sanctions Violations
On July 8, 2025, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Harman International Industries, Inc. (“Harman”) for $1,454,145 to settle potential civil liabilities stemming from eleven apparent...
Key Holdings, Inc. Pays $608,825 for Cuba Sanctions Violations from Failing to Educate Acquired Foreign Subsidiary
On July 2, 2025, The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement for $608,825 with Key Holdings, Inc. (“Key Holdings”), a Delaware-based global logistics company. The settlement resolves potential...
Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers
On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions programs. OFAC identified 12,367 apparent...
Revocation of Syrian Sanctions: Opportunities, Risks, and Changes under Executive Order 14312
President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation of Syria Sanctions” marking a significant...
2025 NAVEX Regional Whistleblowing Benchmark Report: Actionable Insight for Compliance Officers
As compliance and ethics professionals in large, multinational organizations, staying ahead of whistleblowing and incident management trends is critical to fostering a culture of integrity and mitigating risks. NAVEX’s 2025 Regional Whistleblowing & Incident...
Unicat’s $3.88M Sanctions Settlement: the Importance of Voluntary Self-Disclosures Under the DOJ’s M&A Policy
On June 16, 2025, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) entered into a settlement agreement with Unicat Catalyst Technologies, LLC (“Unicat”), for violations of both the Iranian Transactions and Sanctions Regulations (“ITSR”) and...
Navigating the New FCPA Enforcement Guidelines: Key Takeaways for Compliance
On June 9, 2025, the U.S. Department of Justice (DOJ) issued a memorandum from the Deputy Attorney General outlining new guidelines on evaluating whether to investigate and prosecute misconduct under the Foreign Corrupt Practices Act (“FCPA”). This memo—titled...
Important Information for Compliance Professionals from the DOJ’s Corporate Criminal Enforcement Updates
Following the updates to the DOJ’s Corporate Enforcement Policies, there has been a fair amount of conversation as to what the changes mean for compliance. Matt Kelly has a great piece (as always) on his Radical Compliance blog, noting that the materials and AAG...
Updates from the DOJ’s New Corporate Criminal Enforcement Policies
On May 12, 2025, the U.S. Department of Justice Criminal Division’s Assistant Attorney General Matthew R. Galeotti announced changes to the Department’s white-collar criminal enforcement policies. Through his speech at the Securities Industry and Financial...
Trump’s First 100 Days of Trade Compliance: Implications for Compliance Professionals (Part II of II)
In the first part of this series—available here—I provided a background on the changes and underlying motivations of President Trumps actions regarding sanctions and export controls during his first 100 days in office. This second part will provide further information...
Trump’s First 100 Days of Trade Compliance: Key Sanctions Updates and Looking Ahead for Compliance Professionals (Part I of II)
With the first 100 days of the Trump Administration in the books, it’s abundantly clear that trade compliance—whether involving economic sanctions, export controls, or tariffs—will remain a cornerstone of the country’s foreign policy strategy. As such, sanctions...