Lessons in Harman Sanctions Case

harman

We haven’t talked sanctions enforcement lately but now have reason to do so, thanks to an enforcement action last week against a global electronics company that hinged on a weak compliance program and poor oversight of international distributors.  Said company is Harman International, headquartered in Connecticut and a subsidiary of Samsung since 2017. Harman agreed…

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Texas Firm Notches NPA on Sanctions Woes

Unicat

A private equity firm in Texas has avoided prosecution for egregious sanctions violations committed by one of its portfolio companies, in a case that offers all sorts of lessons about corporate compliance in the Trump 2.0 Administration. Let’s take a look. The PE firm in question is White Deer Management, which in 2020 acquired a…

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Italian Firm Dinged on NK Sanctions

sanctions

Don’t die of surprise here, but we have yet another foreign company with a weak sanctions compliance program, conducting business with North Korea through the U.S. banking system, and yet again ending up with a sanctions enforcement action from U.S. regulators. Rinse, repeat. The company in question is Mondo TV, an Italian animation company. It…

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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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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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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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