On March 25, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that PayPal Inc. (“PayPal”) agreed to pay $7.7 million to settle 486 violations of U.S. economic sanctions.  According to OFAC, for several years until 2013, PayPal, one of the world’s largest electronic payment companies, did not have adequate compliance processes to “identify, interdict, and prevent” transactions that were in apparent violation of OFAC sanctions programs.  Specifically, PayPal did not employ adequate screening procedures and technology to identify transactions involving U.S. sanctions targets.
Continue Reading Paying the Piper: PayPal Inc. Settles Sanctions Violations with OFAC for $7.7 Million

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of time for leisure and family. Indeed, most attempts by the country to preserve la vie Française are idealistic efforts to protect what I see as a beautiful way of life (perhaps excluding some of the Académie Française’s more laughable efforts to provide French alternatives to borrowed English words). And some of the country’s biggest companies represent not only the economic engines of France but also embody national pride in global market power.
Continue Reading BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

By: David Gallacher and Thaddeus McBride

In 2011, the world experienced historic events, particularly with regard to the Arab Spring and the violent repression that followed in nations like Libya and Syria.  2011 witnessed the expansion of a number of international sanctions programs, most particularly tied to political developments in countries such as Iran, Syria, Libya, Sudan, Cuba, and North Korea.  Following is a summary of key developments in U.S. sanctions during 2011, as well as a brief look ahead at what may happen in 2012 in countries such as Iran, Yemen, and Myanmar (Burma). 

Continue Reading International Sanctions – Updates to U.S. Sanctions Laws in 2011