You are reading the November 2024 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

  • Department of Homeland Security (DHS) adds almost 30 entities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
  • The Treasury Department’s Office of Foreign Assets Control (OFAC) designates Gazprombank and other Russian financial institutions and parties.
  • OFAC imposes a $1.1 million penalty against a U.S. person for violating the Iranian Transactions and Sanctions Regulations (ITSR).
  • American Life Insurance Company settles with OFAC to resolve allegations it had provided insurance policies to entities affiliated with the government of Iran.
  • Telefónica Venezolana agrees to pay the Department of Justice (DOJ) over $85 Million to resolve an investigation into Foreign Corrupt Practices Act (FCPA) violations.

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Photo of Faith Dibble Faith Dibble

Faith Dibble counsels clients as they navigate the complex regulations associated with a global marketplace. She advises clients on international trade and complex cross-border transactions, investigations, and regulatory and compliance matters relating to U.S. national security.

Read more about Faith Dibble
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.

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