Corruption Crime & Compliance 2024 DOJ and OFAC Sanctions Enforcement and Compliance Review
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Jan 20, 2025 Dive into the current landscape of aggressive sanctions enforcement and discover how companies can keep up with the DOJ's evolving priorities. Learn about record-breaking prosecutions, including 70 individuals in 2024, and insights into OFAC's innovative enforcement strategies. Hear key lessons from high-profile compliance failures and the critical importance of sanctions adherence, especially during mergers and acquisitions. Get predictions on heightened scrutiny of trade with China and insights on navigating the complexities of international sanctions.
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Enforcement Trends
- The DOJ focused on prosecuting individuals in 2024, with a record 70 individuals charged.
- OFAC had a slower year, likely due to the complexity of administering Russia sanctions.
EFG International Case
- EFG International paid $3.7 million for processing transactions for sanctioned individuals in Cuba and Russia.
- This highlights the importance of compliance in the securities industry and enhanced due diligence for high-risk clients.
SCG Plastics Case
- SCG Plastics paid $20 million for obfuscating the origin of resin from a joint venture in Iran.
- This case demonstrates OFAC's focus on secondary sanctions, where foreign companies cause US institutions to process prohibited transactions.