On 21st December, Holland & Hart published an article saying that OFAC had agreed a $7,772,102 settlement with Zoltek Companies Inc. to resolve potential civil liability arising from apparent violations of the Belarus Sanctions Regulations – between January 2012 and October 2015, Zoltek violated the sanctions by providing approval to its Hungary-based affiliate to make 26 purchases from a designated Belarusian company. A US company cannot approve transactions by a foreign company that would be prohibited if performed by a US company.
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