You are reading the December 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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- December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance company and California-based virtual currency exchange. In addition, a Belgian national was indicted by the Department of Justice (DOJ) and designated by OFAC after conspiring to illegally procure products for resale in Russia and China.
- There were two notable actions involving Iran this month. The DOJ charged two individuals for allegedly procuring U.S.-origin microelectronics for an Islamic Revolutionary Guard Corps (IRGC) drone program. Also, OFAC agreed with Nasdaq to settle an investigation of sanctions violations committed by Nasdaq’s Armenian subsidiary.
- The DOJ entered into a Deferred Prosecution Agreement (DPA) with Freepoint Commodities, a Connecticut-based commodities trader, for bribing officials at Petróleo Brasileiro S.A. (Petrobras), a Brazilian state-owned oil company, in violation of the Foreign Corrupt Practices Act (FCPA).
- Lastly, a new Executive Order gives the Secretary of Treasury broader authority to take enforcement actions against foreign financial institutions (FFIs), and the Departments of Commerce, Homeland Security, Justice, State, and Treasury issued a first-ever joint note on compliance best practices for the maritime and transportation industry.