Sanctions Compliance Lessons From Recent OFAC Actions

Law360, New York (September 13, 2017, 12:27 PM EDT) -- In August, the Office of Foreign Assets Control announced the resolution of a trio of enforcement actions against U.S.-based and foreign-organized companies that had run afoul of the Iranian Transactions and Sanctions Regulations (ITSR). While the monetary penalties associated with the settlements were relatively modest, these enforcement actions are notable because they illustrate that OFAC is increasingly bringing cases against nonfinancial institutions, taking aggressive jurisdictional and interpretative positions, and focusing its enforcement efforts on penalizing companies that violate the ITSR.

Recent Settlements

COSL Singapore Ltd.

COSL Singapore...
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