OFAC’s Enforcement Cases of 2019

Date: January 30, 2020

Time: Noon-1:00 p.m.

Location: Webinar

2019 was one of the most active enforcement years. Enforcement actions increased from 2018 as OFAC continues to increase its enforcement efforts on non-financial companies. One particular focus area was sanctions enforcement involving M&A transactions, in particular sanctions violations committed by acquired foreign companies post-closing. OFAC imposed penalties because the acquired companies continued to violate U.S. sanctions even though the U.S. acquirers took affirmative steps to try to terminate those dealings.

Other 2019 enforcement actions involved, for example:

  • Imports of materials and other products that originated in embargoed countries;
  • Violations committed by non-U.S. subsidiaries;
  • Screening issues and deficiencies;
  • Russia sanctions violations, including OFAC’s aggregate 50% rule;
  • High-value settlements targeting financial institutions;
  • Blocked vessels;
  • Travel companies and travel insurance; and
  • Debt assignment and collection.

Join us as we go through the key OFAC enforcement actions of 2019 and discuss their implications and enforcement trends. Nixon Peabody’s Alexandra Lopez-Casero will be joined by her colleague, Robert Fisher, a former Massachusetts Assistant Attorney General who spent nearly a decade working for the United States Attorney’s Office in Boston with much of this time as a member of the Public Corruption and Special Investigations Unit, which included enforcement actions involving international trade violations.

For information on how to register, visit the Massachusetts Small Business Development Center Network website.

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