Bass, Berry & Sims attorney Thad McBride examined recent enforcement activity by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and highlighted key takeaways for companies conducting business internationally. In particular, Thad reviewed OFAC’s November 2019 settlements with Apollo Aviation Group LLC (the company agreed to pay $210,600) and Apple, Inc. (the company agreed to pay $466,912). Thad highlighted each settlement as a reminder that “U.S. companies must understand the risks of international supply chains and take appropriate compliance steps to address and monitor those risks.”
As Thad warns, “OFAC expects companies to consider and put in place strengthened compliance measures, hand-in-hand with disclosing the facts of the matter, to demonstrate the company’s commitment to addressing any compliance shortcomings and thereby reducing the chance of future issues. In that sense, companies need to understand that disclosure carries with it both obligations to cooperate with OFAC and the need to work proactively to improve compliance policies, procedures and processes.”
The full article, “Focus on US Economic Sanctions Compliance: OFAC Imposes Fines and Expects More Monitoring,” was published by Report on Supply Chain Compliance on January 24 and is available online.