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...
Trade Compliance
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...
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...