FIRST US SANCTIONS PENALTY FOR US COMPANY APPROVING SUBSIDIARY TO MAKE PURCHASES

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.

https://www.tradesanctions.com/ofac-announces-its-first-sanctions-penalty-based-solely-on-providing-approval-to-a-non-u-s-subsidiary/#more-332

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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