THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 76, February 2019

Screening the use of screening software for OFAC sanctions compliance

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By Christopher R. Brewster, Chris Griner, Gregory Jaeger and Bibek R. Pandey, Stroock www.stroock.com   On 27 November 2018, the Treasury Department’s Office of Foreign Assets Control (‘OFAC’) announced a settlement agreement with a Virginia-based global technology and services company operating in the aviation, electronics, communications and defence sector. The settlement concerned apparent violations of the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589. According to the settlement agreement, the company had shipped products through its distributors in Canada and Russia to an entity in Russia that, although not identified on OFAC’s List of Specially Designated Nationals and Blocked Persons...

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