Our Latest Sanctions Case Study

sanctions

U.S. authorities have fined a now-defunct Thai company $20 million for covering up its business dealings with an Iranian joint-venture partner in the 2010s, giving us yet another opportunity to consider how companies run afoul of U.S. sanctions laws and what compliance measures you should have in place to avoid that. The Office of Foreign…

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Compliance Jobs Report: Dec. 22

Compliance jobs

Our last Compliance Jobs Report of 2023! We have personnel moves to report at Walgreens, Dollar Tree, Arm, Microsoft, and many more! Also news of an internal auditor suing his employer for intimidation, and job leads in technology, airlines, and government service. Happy holidays to all! Always remember that we need your help to make…

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3M Nailed Again, on Sanctions

sanctions

Manufacturing giant 3M Corp. is paying $9.6 million to settle charges that its overseas business units and resellers improperly sold goods into Iran in the 2010s, in a fascinating glimpse of how overseas employees might try to circumvent trade controls.  The settlement was announced by the Office of Foreign Assets Control (OFAC) on Thursday. This…

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Another Sanctions Case to Study

sanctions

We have a fresh sanctions enforcement action to study this week, courtesy of a New Jersey construction company fined $660,000 for its Middle East subsidiary secretly shipping goods to Iran.  The U.S. Office of Foreign Assets Control (OFAC) announced the enforcement action on Wednesday. The company in question, Construction Specialities Inc., will pay the fine…

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BAT’s Big Sanctions Settlement

BAT

Another week, another eye-popping enforcement action in sanctions compliance! This time around it’s British American Tobacco, paying $630 million to settle charges that the company engaged in a long-running scheme to evade U.S. sanctions and sell goods into North Korea. The Justice Department and the Office of Foreign Assets Control (OFAC) announced the settlement jointly…

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Microsoft Fined $3.3M on Sanctions

Microsoft has agreed to pay more than $3.3 million to settle civil charges that its Russia subsidiary violated U.S. sanctions law in the 2010s by covering up sales of Microsoft products to people in Cuba, Iran, and elsewhere.  The settlement was announced on Thursday by the Office of Foreign Assets Control (OFAC) and the Bureau…

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‘Office Space,’ Fraud, and Controls

Office Space

They say that life sometimes imitates art. Now we have an example of that in the world of Sarbanes-Oxley compliance, courtesy of that knucklehead in Seattle charged the other week with embezzling company money just like those characters in the film “Office Space.”  You may have already seen the headlines. A former IT employee at…

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The Bittrex Sanctions Settlement

bittrex

Before we all rush into the weekend, compliance officers should take a look at that enforcement action against cryptocurrency platform Bittrex that was announced earlier this week. It offers some valuable lessons about building a sanctions compliance program on the fly and what regulators expect crypto firms to do for sanctions risk. The enforcement action…

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More Lessons on Sanctions Programs

sanctions

Anyone looking for systemic failures in sanctions compliance and how a company might rectify those issues, look no further than Toll Holdings and the settlement it reached with U.S. regulators on Monday. Toll, a freight forwarding and logistics business based in Australia, agreed to pay $6.1 million to the Office of Foreign Assets Control to…

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FinCEN Offers Red Flags on Russia

Today we return to risks arising from the Ukraine crisis, because FinCEN has just published an alert warning financial firms to watch for transactions that might actually be Russians trying to avoid Western sanctions — including a list of red flags that AML compliance functions should keep on the radar screen. FinCEN published the 10-page…

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