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OFAC-Issued Guidance: A Sanctions Compliance Framework

If you are mystified by your company’s compliance responsibilities related to sanctions, there is help. In 2019 the Department of Treasury’s Office of Foreign Assets Control (OFAC) published new guidance on how to create a framework for an effective sanctions-compliance program. It can help you comply. And if you should inadvertently run afoul of the…

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An OFAC Case Study

On November 25, 2019, Apple Inc. entered an agreement with the U.S. Department of Treasury to pay a civil penalty of $466,912. The fine is to settle the technology giant’s violations of the Foreign Narcotics Kingpin Sanctions resulting from its interactions with a Slovenian company SIS and its owner Savo Stjepanovic, both on the SDN list. How…

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Are You OFAC Compliant? Or Do You Just Think You Are?

Threats to businesses abound, and given that accounts payable issues payments, it is a prime target for criminal perpetrators of all kinds. In addition to preventing myriad fraud schemes, AP must also ensure information protection and avoid unwitting payments to sanctioned entities. This, of course, involves compliance with the U.S. Treasury Department’s Office of Foreign…