On October 15, 2021, the Office of Foreign Assets Control (OFAC) issued an advisory providing sanctions compliance guidance for the virtual currency industry (Guidance). The Guidance follows a series of recent enforcement actions targeting the industry and the designation of a cryptocurrency exchange for facilitating ransomware payments. These developments highlight OFAC’s continued focus on this
The President signed a new Executive Order today making it unlawful to engage in transactions involving digital currency issued by the Venezuelan government. The Executive Order makes official prior guidance from the Office of Foreign Assets Control (OFAC), which stated that dealings related to Venezuelan digital currency would likely be prohibited under existing sanctions.
A settlement agreement between Richemont North America, the parent company of Cartier, and the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions regulations is an important wake up call for U.S. and global retailers, which have often considered themselves to be somewhat outside the scope of U.S. sanctions laws. In truth, the rules apply to all companies and have the greatest application to those that export goods or conduct other international business.
According to OFAC, two Cartier boutiques in the United States sold jewelry to a customer who directed Cartier to …
Continue Reading Sale of Cartier Jewels Triggers OFAC Violations – Luxury Brands Should Be Aware of U.S. Sanctions Risks
A recent suit filed by the U.S. Department of Justice (DOJ) for the forfeiture of nearly $2 million highlights the broad extraterritorial reach of U.S. sanctions laws. On June 14, DOJ filed a complaint to seize funds associated with transactions between several Chinese companies, including Mingzheng International Trading Limited (Mingzheng). Mingzheng and the other companies had been set up as a front and were conducting transactions in U.S. dollars on behalf of North Korea’s Foreign Trade Bank (FTB), a blacklisted Specially Designated National (SDN). The case has two noteworthy lessons, with the latter lesson hopefully more relevant to your company:
Lesson One: Don’t launder money for North Korean SDNs engaged in proliferation schemes. If you want to know more about how North Korea attempts to launder funds, check out this detailed and fascinating report on the topic.
Lesson Two: If you conduct a transaction in U.S. dollars, even if all other aspects of the transaction occur outside of the United States, the U.S. government will likely claim jurisdiction over the transaction.…
Continue Reading US Govt Seeks $1.9 Million In North Korea Sanctions and Money Laundering Case