Blog
OFAC Fines U.S. Real Estate Investor $4.7 Million for Willful Violations Involving Blocked Russian Property
On November 24, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,677,552 civil monetary penalty against an anonymous U.S. individual (referred to only as “U.S. Person-1”) and their Atlanta-based real estate...
Quarterly Trade Compliance Update – November 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. If you would like to be added to the distribution list, please email me at...
Navigating OFAC Sanctions Risks From North Korean Remote Workers
With the continued rise in remote work, companies now face a unique vector for potentially significant sanctions risks that continues to catch even the most vigilant companies off guard. This threat comes from the Democratic People's Republic of Korea “DPRK” or...
OFAC Increases Sanctions on Rosneft and Lukoil, Adding Both to the SDN List
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued full blocking sanctions on Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) pursuant to Executive Order 14024. This...
Cryptocurrency Compliance Lessons from ShapeShift’s OFAC Sanctions Violations
On September 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with ShapeShift AG, which was formerly a prominent cryptocurrency exchange. The company agreed to pay $750,000 to settle its...
Reminder to file your 2025 Annual Report of Blocked Property With OFAC: Due date September 30, 2025
On September 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its “Reminder to File the 2025 Annual Report of Blocked Property.” Entities or persons subject to the reporting requirement under 31 C.F.R. § 501.603 of the...
Fracht FWO Inc. Fined $1.6 million for ‘Reckless Disregard’ of OFAC Sanctions
On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Fracht FWO Inc. (“Fracht”) to settle apparent violations of multiple sanctions programs. Fracht, an international freight...
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...