OFAC’S LATEST SETTLEMENT PROVIDES AN IMPORTANT REMINDER ON STRENGTHENING COMPLIANCE PROGRAMMES

On 30 July, an article from Clifford Chance said that OFAC announced a settlement with Whitford Worldwide Company LLC, a cookware coating manufacturer based in the US, relating to sales by its non-US subsidiaries to Iran that occurred between 2012 and 2015, and allegedly caused by the company’s failure to identify and adequately manage its OFAC risk.  The article says that, while the conduct is more than 5 years old, the settlement provides important reminders for those focused on OFAC compliance and managing related compliance risks.

https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2020/07/Everything-But-the-Kitchen-Sink-OFACs-Latest-Settlement.pdf

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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