Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherBrowse by ChannelAbout the NetworkJoin the NetworkProductsSub-MenuProducts OverviewBlog ProBlog PlusBlog PremierMicrositeSyndication PortalsAbout UsContactSubscribeSupport
Book a Demo
Search
Close

OFAC Settlement Highlights Need for Compliance Training Across Subsidiaries for Multinational Firms

By Trade and Manufacturing Monitor, Eric McClafferty & Wyatt Mince on January 30, 2023
Email this postTweet this postLike this postShare this post on LinkedIn

The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to make payments through third-party agents to Danfoss’s bank account at the branch of a U.S. financial institution located in the United Arab Emirates (“UAE”). These directions apparently came to customers via Danfoss FZCO, Danfoss’s wholly owned UAE entity. 

According to OFAC, the Danish manufacturer of cooling products directed its sanctioned customers to remit payments to the U.S. financial institution in the UAE worth a total value of approximately $17 million.  OFAC indicated that although Danfoss FZCO did not willfully use third-party agents for the purpose of evading sanctions, it ignored or failed to respond to red flags that its activities could be considered in violation of U.S. sanctions regulations. 

The company’s inability to recognize these red flags, according to OFAC, came from deficiencies within its own sanctions compliance program.

OFAC considered Danfoss’s activities to be “non-egregious” (e.g., the transactions did not involve willful or reckless conduct and did not present serious harm to sanctions program objectives) and assessed a maximum civil penalty equal to the sum of the applicable schedule amount for each violation. OFAC did find several mitigating factors, and as a result, OFAC assessed Danfoss’s ultimate penalty to be $4,379,810. 

Having a robust sanctions compliance program in place, and regular compliance training for employees is critical to avoiding these types of penalties.

Photo of Eric McClafferty Eric McClafferty
Read more about Eric McClaffertyEmail
Photo of Wyatt Mince Wyatt Mince
Read more about Wyatt MinceEmail
  • Posted in:
    Corporate & Commercial, International
  • Blog:
    Trade and Manufacturing Monitor
  • Organization:
    Kelley Drye & Warren LLP
  • Article: View Original Source

LexBlog, Inc. logo
Facebook LinkedIn Twitter RSS
Real Lawyers
99 Park Row
  • About LexBlog
  • Careers
  • Press
  • Contact LexBlog
  • Privacy Policy
  • Editorial Policy
  • Disclaimer
  • Terms of Service
  • RSS Terms of Service
  • Products
  • Blog Pro
  • Blog Plus
  • Blog Premier
  • Microsite
  • Syndication Portals
  • LexBlog Community
  • Resource Center
  • 1-800-913-0988
  • Submit a Request
  • Support Center
  • System Status
  • Resource Center
  • Blogging 101

New to the Network

  • Beyond the First 100 Days
  • In the Legal Interest
  • Cooking with SALT
  • The Fiduciary Litigator
  • CCN Mexico Report™
Copyright © 2025, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo