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3/31/15: The US Treasury Department’s Office of Foreign Assets Control (OFAC) and trade sanctions aren’t terms that roll off the tongue the same way as, oh say, the Department of Justice and the FCPA. Still, OFAC has teeth and trade sanctions represent a significant risk for global companies – something that became all too clear...to PayPal when it was charged with failing to adequately screen transactions with sanctioned companies and individuals. PayPal agreed to pay $7.7 million to settle those charges of violating trade sanctions against Iran, Sudan, and Cuba. Richard Cassin’s post on the FCPA blog is worth reading to see what PayPal did, what helped reduce its settlement amount, and where some of the risks are.
