Dj Wolff

Blogs: Data Law Insights, Government Contracts Legal Forum, International Trade Law, Retail & Consumer Products Law Observer

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International Trade Law

OFAC Sanctions 7 Companies, 5 Individuals for Involvement in Iran’s Nuclear Program

By Dj Wolff & Edward Goetz on July 19, 2019

On July 18th, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned seven companies and five individuals involved in the procurement of materials for sanctioned elements of Iran’s nuclear program. Based in Iran, China, and Belgium, these persons allegedly obtained items for Iran’s Centrifuge Technology Company (TESA), an entity previously designated by OFAC for its role in the proliferation of weapons of mass destruction. OFAC alleged that this network of companies and individuals…

International Trade Law

Trump Administration Follows Through on Plans to Tighten Cuban Sanctions

By Dj Wolff, David Baron, Mariana Pendas & Eduardo Mathison on June 6, 2019

On June 4, 2019, the Trump Administration formally implemented its previously announced intent to tighten its Cuban sanctions program. Specifically, on April 17, 2019 the Administration had announced that in response to Cuba’s alleged role in “destabilizing” activities throughout Latin America, particularly in Venezuela and Nicaragua, it would terminate aspects of the relaxations, primarily related to travel, previously implemented by the Obama Administration. Yesterday, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC)…

International Trade Law

OFAC Begins to Solidify Long-Awaited Guidance on Expected Elements for OFAC Compliance Programs

By Carlton Greene, Cari Stinebower, Dj Wolff & Dainia Jabaji on April 8, 2019

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is known for imposing hefty penalties for violations of US economic sanctions, with individual violations amounting to up to US $295,141 or twice the value of the transaction, whichever is greater, per prohibited transaction, and overall penalties sometimes running into the hundreds of millions, or even billions, of dollars. Despite this, OFAC historically has not provided much guidance for companies on the…

International Trade Law

OFAC Puts Shipping Community on Notice with Updates and Expanded Guidance

By Cari Stinebower, Michelle Linderman & Dj Wolff on March 27, 2019

Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for members of the shipping industry—including shipping companies, ship owners, insurance companies, and financial institutions with shipping practices, port operators, and…

Retail & Consumer Products Law Observer

e.l.f. Cosmetics Settles Potential Civil Liability for Apparent Violations of the OFAC North Korea Sanctions Regulations

By Edward Goetz, Frances P. Hadfield & Dj Wolff on February 15, 2019

On January 31, 2019, e.l.f. Cosmetics, Inc. (“ELF”) agreed to pay $996,080 to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations (NKSR). Elf is a cosmetics company headquartered in Oakland, California. (Stephan) ELF appeared to have violated § 510.201(c)1 of the NKSR by importing 156 shipments of false eyelash kits from two suppliers located in the People’s Republic of China (PRC) that contained materials sourced by these…

International Trade Law

OFAC Enforcement Action: Do You Know What Your Subsidiaries Are Doing?

By Dj Wolff, Frances P. Hadfield & Edward Goetz on February 15, 2019

On February 14, 2019, the Office of Foreign Assets Control (OFAC) announced it had assessed a civil monetary penalty of over $5.5 million dollars against AppliChem GmbH (AppliChem) of Darmstadt, Germany (a company that manufactures chemicals and reagents for the pharmaceutical and chemical industries) for 304 violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR). Specifically, OFAC determined that between May 2012 and February 2016, after it had been purchased by…

International Trade Law

Venezuela: OFAC Issues Additional Clarification to Recent Expansion of Sanctions

By Dj Wolff & Alexandra Solórzano on February 12, 2019

On February 11, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GLs) and revised three Frequently Asked Questions (FAQs) relating to the January 28, 2019 designation of Petróleos de Venezuela, S.A. (PdVSA) and the Government of Venezuela. The amended GLs provide further guidance on how to navigate the recently-issued sanctions on PdVSA. Amended GLs: General License 3C (“GL3C”): replaces GL3B by (a) extending the deadline to wind…

International Trade Law

Latest Information on OFAC General Licenses and FAQs Related to Designation of PdVSA

By Dj Wolff, Eduardo Mathison & Alexandra Solórzano on February 5, 2019

On January 31 and February 1, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GLs) relating to the January 28, 2019 designation of Petróleos de Venezuela, S.A. (PdVSA), amended two Venezuela-related Frequently Asked Questions (FAQs), and issued thirteen new FAQs. The new amendments and additions provide additional guidance for navigating the PdVSA sanctions and clarify, to some extent, the scope of authorization in each of the…

International Trade Law

Importer Settles Potential Civil Liability for Apparent Violations of the OFAC North Korea Sanctions Regulations

By Edward Goetz, Frances P. Hadfield & Dj Wolff on January 31, 2019

On January 31, 2019, e.l.f. Cosmetics, Inc. (“ELF”) agreed to pay $996,080 to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations (NKSR). Elf is a cosmetics company headquartered in Oakland, California. ELF appeared to have violated § 510.201(c)1 of the NKSR by importing 156 shipments of false eyelash kits from two suppliers located in the People’s Republic of China (PRC) that contained materials sourced by these suppliers…

International Trade Law

All or Nothing? OFAC Adds PdVSA to the SDN List

By Cari Stinebower, Dj Wolff, Eduardo Mathison & Alexandra Solórzano on January 30, 2019

On January 28, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order (E.O.) 13850 – “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”. Further, OFAC amended General License 3, issued eight (8) new General Licenses, and published a new Frequently Asked Question (FAQ) on the new E.O. – “Taking Additional Steps to Address the National Emergency with Respect…

Dj Wolff

OFAC Sanctions 7 Companies, 5 Individuals for Involvement in Iran’s Nuclear Program

Trump Administration Follows Through on Plans to Tighten Cuban Sanctions

OFAC Begins to Solidify Long-Awaited Guidance on Expected Elements for OFAC Compliance Programs

OFAC Puts Shipping Community on Notice with Updates and Expanded Guidance

e.l.f. Cosmetics Settles Potential Civil Liability for Apparent Violations of the OFAC North Korea Sanctions Regulations

OFAC Enforcement Action: Do You Know What Your Subsidiaries Are Doing?

Venezuela: OFAC Issues Additional Clarification to Recent Expansion of Sanctions

Latest Information on OFAC General Licenses and FAQs Related to Designation of PdVSA

Importer Settles Potential Civil Liability for Apparent Violations of the OFAC North Korea Sanctions Regulations

All or Nothing? OFAC Adds PdVSA to the SDN List

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