On 25 April, OFAC announced that it had reached an agreement with Toll Holdings Limited, an international freight forwarding and logistics company headquartered in Melbourne, Australia.   The apparent violations of various sanctions regimes involved are said to have occurred when Toll originated or received payments through the US financial system involving sanctioned jurisdictions and persons.  Toll agreed to remit $6,131,855 to settle its potential civil liability for 2,958 apparent violations.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

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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