Bass, Berry & Sims attorney Thad McBride examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran. While not the largest settlement this year, Thad points out that the 3M settlement is important for several reasons, including: “as to the complexity of U.S. sanctions; as to the duration of OFAC enforcement actions; and as to the benefits and potential drawbacks of voluntary disclosure.” In the article, Thad examines each of these points in further detail.
The full article, “What Can Be Learned From 3M’s Iran Sanctions Settlement,” was published by Law360 on November 3 and is available online.