Latest / Trade Compliance Brief - Export Control and Sanctions Insights
OFAC Enforcement Case Study: The $3.7M Syrian Sanctions Violation
In this episode of the Trade Compliance Brief, we break down the latest OFAC settlement involving a U.S. person residing abroad. We analyze the 20 violations of the Syrian Sanctions Regulations (SySR) that resulted in a $3.77 million penalty.
Key topics covered:
The definition of a "U.S. Person" and why residency doesn't waive liability.
What constitutes "Reckless Disregard" in the eyes of the Treasury.
Why the termination of a sanctions program does not provide amnesty for past conduct.
Actionable lessons for Global Compliance Programs and risk mitigation.
Link to OFAC…
The skinny
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