OFAC Issues Finding of Violation—but No Penalty—for Sanctions Violations Caused by Compliance System Defects and Human Error

On April 30, 2020, the US Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) issued a Finding of Violation to American Express Travel Related Services Company (“AMEX”). AMEX issued a prepaid travel card to Gerhard Wisser, a specially designated national or “SDN,” and subsequently processed approximately $35,000 in transactions Wisser conducted using the card. AMEX … Read more

US Administration Imposes Targeted Sanctions on Turkey in Relation to Syria

On October 14, 2019, US President Donald Trump signed an Executive Order (the “Order”) authorizing a range of primary and secondary sanctions on the Government of Turkey and affiliated individuals and entities. The Order followed Turkey’s launch of its “Operation Peace Spring” military operation in Syria. Following the release of the Order, the US Department … Read more