Office of Foreign Assets Control (OFAC) Archives

OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

April 5, 2023

By Harold Jackson, Associate Attorney, Braumiller Law Group

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”),[1] layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have reached the forefront of U.S. government enforcement policy. On March 2, 2023,[2] the U.S. Department of the Treasury, Department of Commerce, and Department of Justice released a Joint Compliance Note, which is evidence that the three departments are coordinating to enforce U.S. sanctions and export controls, particularly those on Russia/Belarus activities.

Red Flags for Software and Sanctions – OFAC Enforcement Wells Fargo Case Study

April 5, 2023

By Harold Jackson, Associate Attorney, Braumiller Law Group

On March 30, 2023, Wells Fargo agreed to remit $30,000,000 to settle its penalty liability across multiple sanctions programs with U.S. Department of the Treasury’s Office of Foreign Asset Controls. Across several years, Wells Fargo and its predecessor in Europe, Wachovia Bank, provided software that was used to process transactions with U.S.-sanctioned jurisdictions and persons.

Evaluating the Efficacy of Sanctions on Russia

August 9, 2022

By: Michelle Schulz, Of Counsel Braumiller Law Group

Since the Kremlin’s February 24th invasion of Ukraine, western countries have put in place extensive global financial ramifications. To gauge the extent of effectiveness, one must decipher the numbers behind Russia’s deceiving published economic statistics. One staggering implication of the trade war with the west lies within the entire collapse of the GDP growth acquired in the post-Soviet era.