You are reading the November 2023 Update 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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Overview

  • November saw a flurry of designations involving Russian individuals and entities, including new designations against entities transporting Russian oil below the $60 price cap. The Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of State also targeted a number of entities and individuals.
  • There was a notable Department of Justice (DOJ) enforcement case in which two men were found guilty of violating sanctions on Iran for selling Iranian oil to a Chinese refinery.
  • The Treasury Department settled with Binance, a large cryptocurrency exchange, to resolve allegations of sanctions violations. A fine of almost $1 billion was imposed. The OFAC settlement was undertaken in coordination with an agreement with the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), which further imposed a $3.4 billion penalty—the largest penalty imposed in the history of the Treasury Department.
  • The DOJ entered into Deferred Prosecution Agreements (DPAs) with two British reinsurance companies for bribing Ecuadorian officials in violation of the Foreign Corrupt Practices Act (FCPA).
  • November also saw the Commerce Department’s Bureau of Industry and Security (BIS) bring an anti-boycott enforcement action against a Pennsylvania-based synthetic fiber manufacturer.
  • Lastly, OFAC issued new guidance to help international nongovernmental organizations (NGOs) provide humanitarian aid to Palestinians without running afoul of U.S. sanctions programs.

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Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.