On 8th January, the National Law Review in the US carried an article about the case involving Cobham Holdings Inc, which it describes as “a cautionary tale”.  It appears Cobham had thought, as many do, that if your foreign customer is not found on the sanctions list, your company is free to sell products to that customer.  It had therefore sold silicon switches to Almaz Antey Telecommunications LLC in Russia between 2014 and 2015 when that entity was not named on the OFAC list , and had used software to search for OFAC sanctions, and the customer came up clean.  The article says that Cobham used the software to search for “Almaz Antey Telecom” but not “Almaz Antey.” If it would have searched for the latter, there were numerous hits for entities under the Almaz Antey umbrella.  Cobham was able to reduce the potential fine by agreeing to utilise new and improved screening software, along with a business intelligence tool and new internal checks for high risk transactions.


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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