U.S. company agrees to pay $79,000 to settle transactions in 2016 and 2017 in violation of Ukraine-related sanctions

Company agrees to settle its potential civil liability for apparent violations of the Ukraine-related sanctions

Company violation of the Ukraine-related sanctions

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced a New York-based company has agreed to pay approximately $79,000 to settle its potential civil liability for apparent violations of the Ukraine-related sanctions regulations.

The company provided business information and financial analytics.

As reported in an OFAC release [PDF 178 KB], the apparent violations occurred between August 2016 and October 2017, when the company (and another company that it had acquired) reissued and re-dated multiple invoices in an effort to continue to extend credit to a state-owned Russian oil company, in violation of the debt and equity restrictions under the Ukraine-related sanction rules and applicable executive order. After reissuing and re-dating four invoices to extend the original payment dates, the company ultimately accepted past-due payments totaling $82,500 from the Russian oil company.

OFAC determined that the company did not voluntarily self-disclose the apparent violations and that the apparent violations constituted a non-egregious case.

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com


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