Clif Burns

Clif Burns

Lloyd’s TSB To Pay Record Fine to OFAC

According to this article in The Times, Lloyd’s TSB expects to pay a £180 million fine, or about $350 million, to the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) for transactions with companies and individuals in embargoed countries.…

Boeing Subsidiary Fined for Anti-Boycott Violations

The Bureau of Industry and Security (“BIS”) recently released a settlement agreement pursuant to which Aviall Pte Ltd agreed to pay $3600 for violation of BIS’s antiboycott regulations. Aviall Pte Ltd. is a Singapore-based subsidiary of U.S.-based Aviall, Inc., which…

I’d Like to Teach Iran to Sing

This article in the International Herald Tribune explores the prevalence of American brand name products in Iran and Sudan notwithstanding sanctions that prohibit most exports to the two countries. As we’ve noted before, much of these products are re-exported from…