A recent fine on a U.S. company while simultaneously penalizing the manager of the company's foreign subsidiary after both violated sanctions on Iran seems reflective of the increasingly aggressive nature and number of U.S. enforcement actions taken on sanctions violations during the last few months, according to several Washington trade lawyers. The fine was called “unprecedented” in early February by the Department of the Treasury. After distributing just one penalty through the first eight months of 2018, the Office of Foreign Assets Control doled out six penalties during the last four months of 2018, according to the office's records. And two months through 2019, OFAC already has administered four penalties worth more than $7 million, according to the agency, including a $5.5 million penalty against the German subsidiary of an Illinois-based company on Feb. 14.
The Office of Foreign Assets Control added one entity and made one change to its Specially Designated Nationals List, under Counter Terrorism designations, OFAC said in a March 5 notice. The office added Harakat Al-Nujaba, a terrorism group, and updated information on Arkam ‘Abbas Al-Kabi, an Iraqi national. The terrorist group is associated with Iraq and Syria, according to the notice.
Welcome to the inaugural issue of International Trade Today’s Export Compliance Daily. The International Trade Today editorial staff is pleased to deliver this complimentary launch preview to our community of trade readers for a limited time. This service was developed in response to strong market feedback indicating a dearth of reliable single-source export compliance information.