In this edition of the Global Sanctions Dashboard, we look at the recently expanded sanctions against Iran just as negotiations over a potential US return to the Iran nuclear deal reach their endgame.
First, OFAC announced on July 15 that a U.S. credit card services provider had agreed to pay $430,500 to settle apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations.
Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions.
1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign.
On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North.