OFAC Is Raising The Compliance Bar

Law360 (April 3, 2019, 10:54 AM EDT) -- On March 27, the U.S. Department of the Treasury's Office of Foreign Assets Control, or OFAC, announced a $1.869 million settlement with Stanley Black & Decker Inc. and its Chinese subsidiary, Jiangsu Guoqiang Tools Co. Ltd. (“GQ,” and collectively with SB&D, the “company”), to resolve 23 apparent violations of the Iranian Transactions and Sanctions Regulations, or ITSR.[1] In addition to a civil penalty, the settlement imposes extensive sanctions compliance commitments on the company, backed by a five-year annual certification requirement.

While the SB&D settlement does not represent a significant financial penalty in comparison to other recent actions, it is the most...

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