You are reading the November 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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Overview
- November saw a flurry of designations involving Russian individuals and entities, including new designations against entities transporting Russian oil below the $60 price cap. The Treasury Department's Office of Foreign Assets Control (OFAC) and the Department of State also targeted a number of entities and individuals.
- There was a notable Department of Justice (DOJ) enforcement case in which two men were found guilty of violating sanctions on Iran for selling Iranian oil to a Chinese refinery.
- The Treasury Department settled with Binance, a large cryptocurrency exchange, to resolve allegations of sanctions violations. A fine of almost $1 billion was imposed. The OFAC settlement was undertaken in coordination with an agreement with the Treasury Department's Financial Crimes Enforcement Network (FinCEN), which further imposed a $3.4 billion penalty—the largest penalty imposed in the history of the Treasury Department.
- The DOJ entered into Deferred Prosecution Agreements (DPAs) with two British reinsurance companies for bribing Ecuadorian officials in violation of the Foreign Corrupt Practices Act (FCPA).
- November also saw the Commerce Department's Bureau of Industry and Security (BIS) bring an anti-boycott enforcement action against a Pennsylvania-based synthetic fiber manufacturer.
- Lastly, OFAC issued new guidance to help international nongovernmental organizations (NGOs) provide humanitarian aid to Palestinians without running afoul of U.S. sanctions programs.
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