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North Pole Confirms Nice Children in Cuba and U.S. Received Presents on Christmas

I have received several inquiries regarding the absence this year of the annual Santa vs. OFAC post. The reason, of course, was this press release, set forth below, from October 14, 2016. A quick call by Export Law Blog to…

  • Clif Burns
  • January 3, 2018
  • Iran Sanctions, OFAC

Do Due Diligence or Penalties May Be Due

Dentsply Sirona agreed to pay the Office of Foreign Assets Control (“OFAC”) $1,220,400 to settle charges in connection with 37 unlicensed exports of dental equipment to Iran. The value of the shipments was not stated but it would have been…

  • Clif Burns
  • December 13, 2017
  • 1 Comment
  • BIS, Civil Penalties, Entity List

BIS, For One, Does Not Welcome Our New Robot Overlords

The Bureau of Industry and Security (“BIS”) recently announced that Pilot Air Freight had agreed to a $175,000 fine ($75,000 of which was suspended) to settle charges that it had aided and abetted an attempted unlicensed export by one of…

  • Clif Burns
  • December 7, 2017
  • Iran Sanctions, OFAC

OFAC Issues Finding of Violation to Foreign Ship Registry for Dealings with Iran

Last Tuesday the Office of Foreign Assets Control (“OFAC”) issued a “finding of violation” (but not a fine) against the Dominica Maritime Registry (“DMR”) for entering into a “Binding Memorandum of Understanding” with the National Iranian Tanker Company (“NITC”), an…

  • Clif Burns
  • December 5, 2017
  • Cuba Sanctions, Foreign Countermeasures, General, OFAC

OFAC Fines Foreign Company for Following Applicable Foreign Law

The Office of Foreign Assets Control (“OFAC”) recently announced that it has extracted $204,277 from American Express as a result of 1,818 credit card transactions in the amount of $583,649.43 for purchases made in Cuba. At issue were Mastercard and…

  • Clif Burns
  • December 1, 2017
  • 1 Comment
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