You are reading the March 2023 edition of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.

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March saw several new enforcement actions and policy updates. Two U.S. citizens were arrested after illegally exporting avionics equipment to Russia; the Department of Justice (DOJ) broke up an illegal procurement network supporting the Iranian drone industry; and the Treasury Department’s Office of Foreign Assets Control (OFAC) announced two settlements for sanctions violations. Let’s jump in!

Overview

• We saw two notable Russia-related enforcement actions in March. In one, the DOJ unsealed a warrant for the seizure of a PJSC Rosneft Boeing 737. In the other, two Kansas men were arrested for illegally exporting avionics equipment to Russia.
• Iran was also the focus of U.S. government enforcement actions. The DOJ broke up an illegal Iranian procurement network and issued two related indictments. In addition, an Iranian national was indicted for illegal exports, and OFAC designated 39 entities for their involvement in an Iranian “shadow banking” network.
• OFAC announced settlements with two financial services companies. One of those settlements, involving Wells Fargo, amounted to more than $30,000,000 in penalties.
• March also saw notable enforcement policy updates. First, Deputy Attorney General Lisa Monaco proclaimed that companies stand on the “front lines of today’s national security challenges” as she announced a new pilot program for companies to claim penalty credit for funds clawed back from offenders. Also, the DOJ, OFAC, and the Commerce Department’s Bureau of Industry and Security (BIS) released a joint compliance note on Russia-related sanctions evasion to help companies comply with relevant trade laws.

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