Tag Archives: OFAC

The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions against Iran and Sudan. The amount paid by Commerzbank under the settlement will not be shocking to those who … Continue Reading

Paying the Piper: PayPal Inc. Settles Sanctions Violations with OFAC for $7.7 Million

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 … Continue Reading

Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act

On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently designated as a terrorist organization by the U.S. Treasury Department, Office of Foreign Assets Control (OFAC), and is listed on the … Continue Reading

OFAC Gets Hot, Bothered on Iran and Cuba: How Economic Sanctions Work Today

By: Scott Maberry and Mark Jensen People who practice U.S. economic sanctions law like to talk about how sanctions are policy-oriented, or an engine of U.S. foreign policy.  Whereas some laws may be more opaquely political, economic sanctions and embargoes seem to express most bluntly how international leverage works through regulation.  And yet, a few recent regulatory developments show that the direction that sanctions take is not always predictable. … Continue Reading

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

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
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