2019 Recap Background
Export Compliance Daily is providing this recap of sanctions and export controls enforcement over the past year. Intended to assist export compliance professionals, lawyers and others in the export world stay up to date with current enforcement trends, this guide includes summaries of prominent enforcement actions by the Treasury's Office of Foreign Assets Controls, the Commerce Department's Bureau of Industry and Security, and the Justice Department since Export Compliance Daily began publishing in March 2019.
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Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
OFAC was particularly active in 2019, reaching the highest amount in civil penalties collected since the agency began compiling the total in 2008. Collections were buoyed by two massive penalties of more than $600 million each against UniCredit Bank and Standard Chartered Bank. Another case that highlighted compliance risks was OFAC’s recent penalty against Apple, which was issued partly because Apple’s sanctions screening software did not properly match names on OFAC’s Specially Designated Nationals List with names in Apple’s database.
The following summary is divided into three parts: part one details OFAC administrative actions, and part two includes administrative cases from BIS. Part three of this summary is a compilation of articles about Justice Department cases related to export controls and sanctions that resulted in convictions, settlements and fines for violators.