Key Points:

• Long-arm of U.S. sanctions jurisdiction reaches conduct by European company.
• Violation involved shipment to Iran from Australia, a close U.S. ally.

On December 3, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that Aiotec GmbH, a German supplier of industrial equipment for the energy sector, agreed to pay $14,550,000 to settle its potential civil liability for violating the Iranian Transactions and Sanctions Regulations (ITSR). The settlement agreement can be found here. The press release can be found here.Continue Reading German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran

On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had violated multiple U.S. sanctions regimes. Continue Reading Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations

I recently shared insights on the landscape of U.S. sanctions on Russia for a story in The Washington Post entitled “Why the U.S. Put a $1 Million Bounty on a Russian Yacht’s Alleged Manager.”Continue Reading Insights on Russian Sanctions in The Washington Post

In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran. Continue Reading Examining the 3M Sanctions Settlement