US Cos. With Foreign Affiliates Should Note OFAC Settlement

Law360 (May 21, 2019, 4:32 PM EDT) -- The U.S. Treasury Department's Office of Foreign Assets Control recently provided new guidance on what compliance measures it expects from U.S. companies with foreign affiliates. This guidance raised the bar on U.S. companies’ responsibility for the actions of their foreign affiliates.

OFAC reached a settlement with U.S.-based company Stanley Black & Decker Inc., or SB&D, and its Chinese subsidiary, Jiangsu Guoqiang Tools Co. Ltd., or GQ, on March 27, 2019, for GQ’s breach of U.S. sanctions. Pursuant to the settlement, SB&D agreed to pay $1.87 million for GQ’s export of products to Iran in violation of U.S. law.

In its settlement...

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