Trade Compliance Brief - Export Control and Sanctions Insights

OFAC Enforcement Case Study: The $3.7M Syrian Sanctions Violation


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In this episode of the Trade Compliance Brief, we break down the latest OFAC settlement involving a U.S. person residing abroad. We analyze the 20 violations of the Syrian Sanctions Regulations (SySR) that resulted in a $3.77 million penalty.

Key topics covered:

  • The definition of a "U.S. Person" and why residency doesn't waive liability.
  • What constitutes "Reckless Disregard" in the eyes of the Treasury.
  • Why the termination of a sanctions program does not provide amnesty for past conduct.
  • Actionable lessons for Global Compliance Programs and risk mitigation.


Link to OFAC enforcement release document: https://ofac.treasury.gov/media/935041/download?inline

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Trade Compliance Brief - Export Control and Sanctions InsightsBy Pete